Stanley Drilling Equipment OFAC Settlement: $84.2K

Between June 16, 2008, and October 17, 2008, Stanley Drilling attempted to export four shipments and successfully exported two shipments of goods, valued at $93,329, from the United States to the United Arab Emirates, with reason to know that the shipments were intended specifically for supply, transshipment, or reexportation to an oil drilling rig located in Iranian waters.

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 $156,000. The settlement amount of $84,240 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: Stanley Drilling did not have an OFAC compliance program in place at the time of the violations; the transactions were particularly harmful to U.S. sanctions program objectives because they aided the development of Iranian petroleum resources; the harm to OFAC sanctions program objectives was lessened because four of the six shipments were detained prior to leaving the United States; Stanley Drilling did not appear to have actual knowledge that the drilling rig was destined for or located in Iranian waters at the time of the subject transactions (although Stanley Drilling had reason to know these facts, because they were publicly and readily available before and at the time of the subject transactions); Stanley Drilling is a small company; and Stanley Drilling has no history of prior OFAC violations.

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