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Company Gets Mitigated Penalty for Supplying Fuel to Iranian Vessel

Wednesday, April 02, 2014
Sandler, Travis & Rosenberg Trade Report

The Treasury Department’s Office of Foreign Assets Control announced March 31 that a Pennsylvania company has agreed to pay $157,500 for supplying bunker fuel in Brazil for an Iranian vessel carrying an agricultural commodity, which OFAC alleges violated the Iranian Transactions and Sanctions Regulations. This transaction occurred in November 2008 and was valued at $513,141.

The maximum statutory penalty amount for the alleged violation was $1,026,283 and the base penalty amount was $250,000. On one hand, OFAC states, the company had prior notice that supplying bunker fuel to Iranian vessels could violate the ITSR and did not make a voluntary self-disclosure. On the other hand, the alleged violation did not constitute an egregious case and the company was a small entity, has not received a penalty notice or finding of violation from OFAC in the past five years, and cooperated with the investigation by agreeing to toll the statute of limitations.

ST&R will be hosting a webinar on the nuts and bolts of OFAC compliance April 15. Click here for more information or to register.

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