The Treasury Department’s Office of Foreign Assets Control reports that an international freight forwarder based in the U.S. has agreed to pay $1.6 million to settle its potential civil liability for apparent violations of multiple OFAC sanctions programs. OFAC explains that the forwarder, by failing to undertake sanctions screening or internal legal review (contrary to its own compliance policies and procedures), contracted with a blocked government of Venezuela airline to transport goods from Mexico to Argentina, which was done using a separately blocked aircraft operated by an Iranian company and crewed by Iranian nationals.
According to OFAC, the base civil monetary penalty applicable in this matter is the statutory maximum of $2.15 million. Aggravating factors included the company’s failure to voluntarily self-disclose the apparent violations and its reckless disregard for U.S. sanctions requirements despite being a large and sophisticated international organization. Mitigating factors included the company’s substantial cooperation with OFAC’s investigation as well as its remedial measures, which included “accelerating its broad and significant sanctions and compliance improvements that were already underway,” such as modifying its air freight cargo contract templates, hiring additional sanctions compliance personnel, committing significant financial resources to compliance, and enhancing its auditing procedures.
More broadly, OFAC states, this enforcement action emphasizes the importance for international trade service providers to know their counterparties and recognize the risks of prioritizing urgent business demands at the expense of compliance. “In a complex operating environment,” OFAC adds, “it is critical for all persons subject to U.S. jurisdiction—including senior personnel responding to urgent commercial needs—to understand potential sources of sanctions risk and take appropriate steps to prevent potential violations.”
Copyright © 2026 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.