OFAC Posts Recent Civil Penalties Cases

The Department of the Treasury's Office of Foreign Assets Controls (OFAC) published recent civil penalty information: 

On September 26, 2013, OFAC assessed a penalty of $750,000 against Finans Kiymetli Madenler Turizm Otomotiv Gida Tekstil San. Ve Tic (FINANS), a Turkey-based trading company, for violating the Iranian Transactions and Sanctions Regulations (ITSR).  Specifically, OFAC determined that in 2012, FINANS violated the prohibition against the exportation of services to Iran when it made at least three funds transfers via banks in the U.S., totaling $257,808, to the Iranian government and/or persons.

FINANS did not voluntarily disclose the violations to OFAC and the violations constituted an egregious case. The base penalty amount for the violations was $750,000.  In assessing the penalty amount, OFAC considered, among other factors, that FINANS' senior management had reason to know of the conduct that lead to the violations, and FINANS did not have a compliance program in place. 

On October 21, 2013, OFAC assessed a penalty of $1,500,000 against Alma Investment LLC (Alma), a UAE-based investment and advising company that also appears to serve as a general trading company, for violating the Iranian Transactions and Sanctions Regulations (ITSR). Specifically, on at least six occasions in 2009 and 2010, Alma originated electronic funds transfers, totaling $103,283, that were processed through financial institutions in the U.S. for the benefit of persons in Iran.  OFAC determined that Alma violated the prohibition against the exportation of services from the U.S. to Iran.

The violations constituted an egregious case and Alma did not voluntarily self-disclose the violations to OFAC.