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California Company Fined $65,000 for Shipments to Sudan and Iran

Monday, June 30, 2014
Sandler, Travis & Rosenberg Trade Report

The Treasury Department’s Office of Foreign Assets Control announced June 25 that a company headquartered in California has agreed to pay $64,758 to settle potential civil liability for apparent violations of the U.S. sanctions against Sudan and Iran. The company was charged with exporting 16 shipments of networking equipment and related accessories to Sudan and two shipments to Iran over a three-year period.

The base penalty amount for the apparent violations was $143,906, and the settlement amount reflects OFAC’s consideration of certain facts and circumstances. One the one hand, the company is “sophisticated” but demonstrated reckless disregard for U.S. sanctions requirements by engaging in worldwide commerce without implementing even basic OFAC compliance measures, and the apparent violations constitute a pattern of conduct. On the other hand, the company has no prior sanctions history, voluntarily self-disclosed this matter to OFAC, took prompt corrective action and cooperated with OFAC’s investigation.

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