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OFAC Penalizes Florida Company for Attempted Export to Iran

Friday, October 28, 2011
Sandler, Travis & Rosenberg Trade Report

The Treasury Department’s Office of Foreign Assets Control has assessed a $7,000 penalty against a Florida company for attempting to export goods to Iran on behalf of a foreign customer. OFAC determined that the company did not voluntarily self-disclose the violation, which constituted a non-egregious case. The final penalty was reduced from the base amount of $10,000 in light of the following facts and circumstances: the company had knowledge or reason to know that the goods were destined for Iran, did not have an OFAC compliance program in place at the time of the violation and had not been the subject of an OFAC enforcement action in the five years preceding the transaction at issue, and some of the goods the company attempted to ship appear to have been eligible for an OFAC license had an application been submitted.

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