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Fuel Company Fined for Sales Involving Iran, Sudan and Cuba

Thursday, September 12, 2013
Sandler, Travis & Rosenberg Trade Report

The Treasury Department’s Office of Foreign Assets Control announced Sept. 9 that a Florida company has agreed to pay $39,501 to settle potential civil liability for alleged violations of the Iranian Transactions Regulations, the Sudanese Sanctions Regulations  and the Cuban Assets Control Regulations. The alleged violations involve the company’s facilitation of a sale by one of its non-U.S. affiliates of fuel for a vessel at port in Iran, the facilitation by a U.S. subsidiary of services and fuel purchases for an aircraft that stopped in Sudan, and coordination services provided by two U.S. subsidiaries for 30 unlicensed flights to Cuba.

The total transaction value for the alleged violations was $79,219 and the base penalty was $73,151. OFAC mitigated the penalty after determining that the company voluntarily self-disclosed some of the alleged violations (none of which were egregious), has no history of prior OFAC violations, cooperated with OFAC’s investigation and has enhanced its OFAC compliance plan.

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