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Exports to UAE for Iran Oil Rig Yield $84,000 Penalty

Monday, July 22, 2013
Sandler, Travis & Rosenberg Trade Report

The Treasury Department’s Office of Foreign Assets Control announced July 19 that a Texas company has agreed to pay $84,240 to settle potential civil liability associated with charges that it exported and attempted to export goods to the United Arab Emirates that it had reason to know were intended for an oil drilling rig located in Iranian waters.

The base penalty amount for the alleged violations was $156,000. Aggravating factors include that the matter was not voluntarily disclosed to OFAC, the company did not have an OFAC compliance program in place at the time of the alleged violations, and the transactions were particularly harmful to U.S. sanctions program objectives because they aided the development of Iranian petroleum resources. On the other hand, the alleged violations constitute a non-egregious case, the harm to OFAC sanctions program objectives was lessened because four of the six shipments were detained prior to leaving the U.S., the company did not appear to have actual knowledge that the drilling rig was destined for or located in Iranian waters at the time of the subject transactions (although it had reason to know these facts because they were publicly and readily available before and at the time of the subject transactions), and the company is small and has no history of prior OFAC violations.

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