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Findings of Violation Issued for Insufficient Reporting to OFAC

Monday, August 12, 2019
Sandler, Travis & Rosenberg Trade Report

The Office of Foreign Assets Control has issued separate findings of violation to the following companies for the conduct indicated.

For more information on export compliance and avoiding penalties, please contact export compliance attorney Kristine Pirnia at (202) 730-4964.

- A Florida company failed to provide complete information in response to an administrative subpoena demanding detailed information, descriptions, and documents regarding the sale of helicopters destined for Iran via an Iranian businessman based in Ecuador. Aggravating factors included the company’s “reckless disregard” for U.S. sanctions requirements, actual knowledge or reason to know of the conduct at issue, and failure to fully cooperate with OFAC’s investigation. Mitigating factors included the company’s apparent status as a small to medium-sized business and its lack of any prior OFAC sanctions history.

- A Virginia company provided contradictory, false, materially inaccurate, materially incomplete, and misleading statements to OFAC during the pendency of an investigation of the company’s involvement in the facilitation of the shipment, supply, and sale of farm equipment to Sudan. Aggravating factors included the company’s reckless disregard for its U.S. sanctions requirements, knowledge that its responses to OFAC were inaccurate, and failure to correct its responses when given the opportunity. Mitigating factors included the company’s apparent status as a small business and its lack of prior OFAC sanctions history and the fact that its responses appear to have been filtered through its outside attorney.

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