Sogda Limited, Inc. OFAC Settlement: $128.2K (2012)

Between March 25, 2009 and August 26, 2010, Sogda engaged in seven export transactions that involved the transshipment of goods through Bandar Abbas, Iran, in alleged violation of the Iranian Transactions Regulations.

This matter was not voluntarily disclosed to OFAC, and the alleged violations constitute a non-egregious case. The base penalty amount for the alleged violations was $570,000. The settlement amount of $128,250 reflects OFAC's consideration of the following facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, App. A: Sogda had no history of prior OFAC violations; Sogda undertook remedial measures by creating an OFAC compliance program; and Sogda cooperated with OFAC by providing information regarding substantially similar additional transactions of which OFAC had not been aware.

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