Zurigo Trading, Inc. OFAC Civil Penalty: $7K (2011)

In September 2006, Zurigo attempted to export goods valued at $7,168 to Iran on behalf of its foreign customer, violating the Iranian Transactions Regulations, 31 C.F.R. part 560.

Zurigo did not voluntarily self-disclose the violation to OFAC, and OFAC determined the violation constituted a non-egregious case. The base penalty amount was $10,000. The assessed penalty of $7,000 reflects OFAC's consideration of the following facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines: Zurigo had knowledge or reason to know that the goods were destined for Iran; Zurigo did not have an OFAC compliance program in place at the time of the violation; Zurigo has not been the subject of an OFAC enforcement action in the five years preceding the transaction at issue; and some of the goods Zurigo attempted to ship appear to have been eligible for an OFAC license had an application been submitted to OFAC.

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