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Practice Areas

Turkish Trading Company Fined $750,000 for Funds Transfers for Iranian Government

Wednesday, October 02, 2013
Sandler, Travis & Rosenberg Trade Report

The Treasury Department’s Office of Foreign Assets Control has assessed a penalty of $750,000 on a Turkey-based trading company for violating the prohibition against the direct or indirect exportation of services from the U.S. to Iran or the government of Iran. According to OFAC, this company originated at least three electronic funds transfers totaling $257,808 that were processed through financial institutions located in the U.S. for the benefit of the government of Iran and/or persons in Iran. Two of those transactions were blocked by the U.S. financial institution.

OFAC did not mitigate the final penalty from the base amount, noting among other things that the company did not voluntarily self-disclose the violations, acted recklessly by concealing and/or omitting material information in funds transfers, does not appear to have an OFAC compliance program and did not cooperate with OFAC during the course of its investigation. OFAC also believes that a civil monetary penalty will have a compliance/deterrence effect by encouraging greater due diligence by foreign financial institutions that maintain accounts for third-country trading companies.

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