Toyota Motor Credit Corporation OFAC Settlement: $23.4K

Between April 6, 2008, and June 30, 2010, TMCC maintained a loan account for, and processed instead of blocked, 26 loan payments totaling $14,449 on behalf of Claudia Aguirre Sanchez. OFAC had designated Aguirre Sanchez as a Specially Designated Narcotics Trafficker pursuant to the Foreign Narcotics Kingpin Designation Act, 21 U.S.C. 1901 et seq., and added her to the Specially Designated Nationals and Blocked Persons List on December 12, 2007 — more than four months before the first transaction. All 26 apparent violations related to one account and constituted apparent violations of the Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598.

OFAC determined that TMCC did not voluntarily self-disclose the apparent violations and that the apparent violations constituted a non-egregious case. The total base penalty amount was $26,000. The settlement amount of $23,400 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. Mitigation was extended because TMCC had not received a penalty notice or Finding of Violation from OFAC in the five years preceding the date of the transactions; the apparent violations likely would have been licensed by OFAC under licensing policy existing at the time; TMCC cooperated with OFAC throughout its investigation; and TMCC took appropriate remedial action in response to the apparent violations. This mitigation was offset by aggravating factors.

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