Robbins Instruments OFAC Settlement: $37.1K (2011)

Robbins exported, sold, and/or supplied medical equipment to one or more individuals in Iran without a license from OFAC. The apparent violations involved 13 separate transactions valued at $37,029, occurring between October 2005 and November 2009.

Robbins did not voluntarily self-disclose the matter to OFAC, and OFAC determined the apparent violations constituted a non-egregious case. The base penalty amount for the apparent violations totaled $103,000. The settlement amount of $37,080 reflects OFAC's consideration of the General Factors: Robbins continued to engage in trade-related transactions involving Iran despite receiving notice of its apparent violation, demonstrating recklessness; Robbins did not have a compliance program in place at the time of the apparent violations; Robbins had not previously been the subject of an OFAC enforcement action; the export of the medical equipment at issue likely would have been licensed by OFAC under existing licensing policy; and Robbins cooperated with OFAC by agreeing to toll the statute of limitations.

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