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California Company Fined $85,000 for Exports of Marine Antenna Systems for Iranian Ships

Friday, April 04, 2014
Sandler, Travis & Rosenberg Trade Report

The Treasury Department’s Office of Foreign Assets Control announced April 2 that a California company has agreed to pay $85,113 to settle potential civil liability for apparent violations of the Iranian Transactions and Sanctions Regulations. OFAC states that this company invoiced a distributor in South Korea for 16 orders of marine antenna systems with a total value of $378,281 and exported those systems to its distributor with knowledge or reason to know that they were intended for installation and use on vessels owned by the National Iranian Tanker Company.

The base penalty amount for the apparent violations was $189,141. On the one hand, OFAC states, the apparent violations constitute a non-egregious case and the company’s first violation, and the company voluntarily disclosed the matter to OFAC, had an OFAC compliance program in place at the time of at least six of the apparent violations, and has undertaken some remedial steps and provided some cooperation to OFAC. On the other hand, the shipments caused harm to U.S. sanctions objectives, the company showed “reckless disregard for U.S. sanctions” by making the shipments without adequate due diligence, the reckless conduct constituted a pattern, a company sales manager had reason to know the antenna systems were destined for NITC, and the company is “a sophisticated international business that should have had more than just general policies and procedures in place to ensure OFAC compliance, including appropriate mechanisms to determine the location of, and other information related to, the ultimate purchasers or users of its products.”

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