Background

An Oregon company has agreed to pay $43,200 to settle potential civil liability for alleged violations of the Iranian Transactions and Sanctions Regulations, the Treasury Department’s Office of Foreign Assets Control announced Sept. 7. The alleged violations involve the exportation of seven shipments of orthodontic devices from the U.S. to Germany, the United Arab Emirates, and/or Lebanon with knowledge or reason to know that the shipments were intended specifically for supply, transshipment, or reexportation to Iran.

The maximum statutory civil penalty amount for the alleged violations was $1.75 million and the base penalty amount was $80,000. OFAC determined that the company did not voluntarily self-disclose the alleged violations but that they constitute a non-egregious case.

OFAC considered the following to be aggravating factors: (1) the company willfully violated U.S. sanctions laws, (2) company management had actual knowledge or reason to know that the company’s products were being exported to Iran, and (3) the company had no OFAC compliance program in place until June 2008.

OFAC considered the following to be mitigating factors: (1) the alleged violations did not result in great economic or other benefit to Iran because the transactions likely would have been licensed by OFAC had the company applied for a license, (2) the company has no sanctions history with OFAC for the five years preceding the date of the first transaction giving rise to the alleged violations, (3) the company cooperated with OFAC by agreeing to toll the statute of limitations, (4) the company developed an economic sanctions compliance procedure in June 2008 and subsequently drafted a written compliance policy, and (5) the company lacked commercial sophistication in conducting international sales at the time of the alleged violations.

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