The U.S. Office of Foreign Assets Controls (OFAC) posted recent civil penalty enforcement information on their website:
On October 19, 2012, Brasseler USA, a Savannah, GA, medical supply company, has agreed to pay $18,900 to settle potential civil liability for alleged violations of the Iranian Transaction Regulations (ITR) from 2006 to 2009. Specifically, OFAC alleged that on three separate occasions, Brasseler exported goods or services to a person in a third country with knowledge that they were intended specifically for transshipment to Iran, without authorization from OFAC. The total of the transactions amounted to $5,241. Brasseler did not voluntarily self-disclose the matter to OFAC. According to OFAC, the alleged violations constituted a non-egregious case, and the base penalty amount for the violations totaled $21,000.
On November 15, 2012, Sogda Limited, Inc., a Kirkland, WA company, has agreed to pay $128,250 to settle potential civil liability for alleged violations of the Iranian Transactions Regulations (ITR). The alleged violations occurred between March 25, 2009 and August 26, 2010, when the company engaged in seven export transactions that involved the transshipment of goods through Iran.
The company did not voluntarily disclose the matter to OFAC. The alleged violations constituted a non-egregious case, and the base penalty amount for the alleged violations was $570,000.