Sea Tel Inc. OFAC Settlement: $85.1K (2014)

Between November 20, 2007, and February 26, 2009, Sea Tel invoiced its distributor, Shindong Digitech Co. Ltd., in South Korea for 16 orders of marine antenna systems, with a total value of $378,281, and exported the antenna systems to its distributor with knowledge or reason to know that they were intended specifically for reexportation, directly or indirectly, to Iran. The antenna systems were for installation and use on vessels owned by the National Iranian Tanker Company ("NITC"), an Iranian entity. A Sea Tel sales manager had reason to know that the antenna systems were destined for NITC and authorized the shipments.

This matter was voluntarily disclosed to OFAC by Sea Tel and the apparent violations constitute a non-egregious case. The base penalty amount for the apparent violations was $189,141. The settlement amount of $85,113 reflects OFAC's consideration of the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

Sea Tel is a sophisticated international business that should have had more than just general policies and procedures in place to ensure OFAC compliance, including appropriate mechanisms to determine the location of, and other information related to, the ultimate purchasers or users of its products. Sea Tel showed reckless disregard for U.S. sanctions by shipping goods for reexport to NITC without adequate due diligence, and its reckless conduct constituted a pattern, providing antenna systems on 16 occasions over 15 months.

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