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Puerto Rico Company Fined for Purchases from Blocked Entity

Monday, August 04, 2014
Sandler, Travis & Rosenberg Trade Report

The Treasury Department’s Office of Foreign Assets Control reports that a Puerto Rico company has agreed to pay $27,000 to settle potential civil liability for six apparent violations of the Narcotics Trafficking Sanctions Regulations. OFAC states that from on or about Oct. 9, 2009, to on or about July 21 , 2010, this company made six purchases of frozen passion fruit juice/pulp from a company listed as a Specially Designated Narcotics Trafficker.

The total base penalty amount for the apparent violations was $600,000. The settlement amount reflects the following mitigating factors: the company has not received a penalty notice or finding of violation from OFAC in the five years preceding the date of the earliest transaction giving rise to the apparent violations; the company’s cooperation with OFAC's investigation and taking of appropriate remedial measures by instituting a compliance program; and the individual characteristics of the company, including the size of its operations and financial condition. On the other hand, the company did not have an OFAC compliance program in place at the time of the apparent violations and did not voluntarily self-disclose the apparent violations.

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