From fiscal year 2008 to 2018, in addition to enforcement, OFAC investigations resulted in settlements with businesses totaling more than $2,780,000,000. Yes, that`s $2.7 billion! In addition, OFAC today announced a $16,875 settlement with Alfa Laval Inc. (“AL U.S.”), a company based in Richmond, Virginia. AL U.S. has agreed to settle its potential civil liability for obvious violations of the ITSR on behalf of its former subsidiary (now an operating entity), Alfa Laval Tank, Inc. (“AL Tank”), based in Exton, Pennsylvania. Specifically, the obvious violations were committed between May 2015 and March 2016, when AL Tank, which manufactures and sells storage tank cleaning equipment, returned a well-known Iranian business opportunity to its foreign subsidiary in Dubai. The foreign subsidiary then orchestrated a system of exporting goods from the United States to Iran and did so using AL Tank to export its Gamajet-branded cleaning units to Iran. OFAC noted that AL U.S.
did not voluntarily disclose the obvious violations itself and that the obvious violations are a non-egregious case. The U.S. Treasury Department`s Office of Foreign Assets Control (OFAC) today announced a $2,329,991 settlement with Bank of China (UK) Limited, a financial institution based in London, United Kingdom. BOC UK agreed to transfer $2,329,991 to settle its potential civil liability for processing transactions in flagrant violation of OFAC`s now-defunct Sudan sanctions program, which prohibited the direct or indirect export of goods, technology or services from the United States to Sudan. In particular, between September 4, 2014 and February 24, 2016, BOC UK exported financial services from the United States by processing 111 business transactions totaling $40,599,184 through the U.S. financial system on behalf of parties in Sudan. This settlement amount reflects OFAC`s conclusion that the self-identified obvious violations were voluntarily self-disclosed by BOC UK and constitute a non-egregious case. The U.S. Treasury Department`s Office of Foreign Assets Control (OFAC) today announced a $189,483 settlement with NewTek, Inc. (“NewTek”), a San Antonio, Texas-based company that develops and supplies hardware and software systems for live production and 3D animation.
The agreement governs NewTek`s potential civil liability for obvious violations of Iran`s Transactions and Sanctions Regulations, 31 C.F.R.part 560 (ITSR) that occurred between December 2013 and May 2018, when NewTek indirectly exported goods, technology, and services from the United States to Iran through third-country traders. OFAC noted that NewTek voluntarily disclosed the obvious violations itself and that the obvious violations are a non-egregious case. ==External links==The Treasury Department`s Office of Foreign Assets Control (OFAC) today announced a $133,860 settlement with a U.S. Person-1. U.S.. Person-1, who was a U.S. citizen living in the U.S. at the time of the apparent violations, agreed to settle her possible civil liability for four obvious violations of Iran`s transaction and sanctions provisions, 31.C.F.R.part 560. Specifically, between approximately February 2016 and March 2016, U.S. Person-1 arranged and received four payments on behalf of an Iranian company using a personal bank account in the United States. OFAC noted that U.S. Person-1 did not voluntarily disclose the obvious violations and that the obvious violations constitute a egregious case.
For more information, please refer to the following notice and settlement agreement for the AL Middle East case and the following web notice for the AL U.S. case ==External links==The Office of Foreign Assets Control (OFAC) of the Department of Finance today announced a $415,695 settlement with Alfa Laval Middle East Ltd. (“AL Middle East”), a Dubai-based company based in Dubai, United Arab Emirates, which sells fluid handling equipment and other equipment for energy and other sectors. AL Middle East has agreed to settle its possible civil liability for obvious violations of Iran`s settlements on transactions and sanctions, 31 C.F.R.part 560 (ITSR). Specifically, the apparent violations were committed between May 2015 and March 2016, when AL Middle East conspired with companies based in Dubai and Iran to export Gamajet-branded storage tank cleaning units from the United States to Iran. As a result of this conspiracy, AL Middle East incited its U.S.-based subsidiary to indirectly export goods from the U.S. to Iran by falsely listing a Dubai-based company as an end user in its export documents. The scope of the plot included other incomplete and contemplated export transactions with Iran that would have applied the same regime. OFAC noted that AL Middle East did not voluntarily disclose the obvious violations itself and that the obvious violations constituted a egregious case. Romanian company First Bank SA and its U.S.
parent company JC Flowers & Co. have agreed to transfer $862,318 to settle any possible civil liability for First Bank`s processing of transactions in clear violation of OFAC`s sanctions programs against Iran and Syria. Specifically, First Bank processed 98 business transactions totaling $3,589,189 through U.S. banks on behalf of parties in Iran and Syria. In 2018, after JC Flowers acquired a majority stake in First Bank, First Bank processed euro-denominated payments for people based in Iran. The settlement amount reflects OFAC`s conclusion that the obvious violations were voluntarily disclosed and were not scandalous. For more information, see the following Web note. .
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