Shipping Company Settles OFAC Charges Of Violating WMD Sanctions Regulations

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Cadwalader, Wickersham & Taft LLP

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A U.S.-based shipping and logistics company agreed to settle OFAC charges of violating Weapons of Mass Destruction ("WMD") Proliferators Sanctions Regulations.
United States International Law

A U.S.-based shipping and logistics company agreed to settle OFAC charges of violating Weapons of Mass Destruction ("WMD") Proliferators Sanctions Regulations.

According to the settlement agreement, the respondent, MID-SHIP Group LLC ("MID-SHIP") allegedly processed five electronic funds transfers concerning payments linked to blocked vessels that were owned or controlled by the Islamic Republic of Iran Shipping Lines ("IRISL"). IRISL was designated by OFAC in September 2008 pursuant to Executive Order 13382 ("Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters"). Although many of the potentially prohibited transactions originated with MID-SHIP's subsidiaries in China and elsewhere, OFAC alleged that the company's U.S. headquarters provided accounting support and received commission payments related to these transactions. In addition, OFAC alleged that the company's senior management was aware of certain transactions and may have helped the company to evade detection by financial institution screening tools.

MID-SHIP agreed to pay $871,837 and committed to establishing sanctions compliance measures - consistent with OFAC's new compliance Framework - to prevent similar incidents from occurring in the future.

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