SAN Corporation OFAC Settlement: $22.5K (2013)

OFAC alleged that SAN sold nutritional supplements to an entity in Kuwait with knowledge that such goods were intended for end use in Iran, in apparent violation of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560. The transaction occurred on or about September 30, 2007. SAN had been informed by the Iranian end user that shipping to Iran required an OFAC license.

OFAC determined that SAN did not voluntarily disclose this matter and that the alleged violation constitutes a non-egregious case. The base penalty amount for the alleged violation was $25,000. The settlement amount of $22,500 reflects OFAC's consideration of facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

SAN acted with reckless disregard for U.S. sanctions requirements when it sold goods to an entity in Kuwait with knowledge that the goods were destined for Iran, and having been informed by the Iranian end user that shipping to Iran required an OFAC license. SAN did not fully cooperate with OFAC's investigation, having provided incomplete and/or inaccurate statements to OFAC. The goods SAN sold for end use in Iran appear to have been eligible for a license under the Trade Sanctions Reform and Export Enhancement Act of 2000, indicating a compliant path was available.

This page summarizes an OFAC enforcement case based on the document archived below. SanctionsLookup assumes no liability for errors, omissions, or inaccuracies in the original documents, this summary, or any changes made to the source documents at any time.

Provided for informational purposes only and does not constitute legal or compliance advice. Always consult the source document directly rather than relying on this summary.