The Treasury Department’s Office of Foreign Assets Control reports that a U.S. company has agreed to pay $3.88 million to settle its potential civil liability relating to U.S. sanctions on Iran and Venezuela. OFAC states that between 2016 and 2021 the company’s former chief executive officer and former employees and representatives supplied products and services to customers in Iran and sold goods to a blocked Venezuelan entity.
OFAC states that the statutory maximum civil monetary penalty applicable in this case is $8.04 million and the base penalty is $4.02 million. The settlement amount reflects both aggravating factors – including the willful nature of the violations, knowledge of and participation in the violations by senior management, and attempts to conceal dealings with sanctioned entities – and mitigating factors – including the company’s clean penalty history over the previous five years, cooperation with OFAC’s investigation, and remedial measures, including filing self-disclosures, implementing a sanctions compliance policy, establishing an export and sanctions compliance program, designating global and U.S. trade compliance managers, and regularly training employees on export controls and sanctions.
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