- within International Law, Intellectual Property, Litigation and Mediation & Arbitration topic(s)
A U.S. individual settled potential civil liability with OFAC for alleged violations of the Iranian Transactions and Sanctions Regulations ("ITSR").
According to OFAC, the individual accepted four payments into his personal U.S. bank account on behalf of an Iran-based cement company that totaled $133,860. OFAC found that (i) the payments were for an Iranian-origin cement precursor that the Iranian company was supplying to a project in another country, and (ii) the individual helped to organize and enable the sale of the product alongside a family member working at the Iranian company. OFAC stated that the individual was, or should have been, aware that his activity was prohibited, considering that OFAC had previously denied an application from the individual for authorization to transact with Iran.
OFAC found that the individual violated Rules 560.204 ("Prohibited exportation, reexportation, sale, or supply of goods, technology, or services"), 560.206 ("Prohibited trade-related transactions") and 560.208 ("Prohibited facilitation by United States persons of transactions by foreign persons") of the ITSR by (i) exporting financial services to an Iranian company, (ii) engaging in commercial dealings involving the sale of an Iranian-origin product and (iii) facilitating transactions with Iran. The violations were not voluntarily self-disclosed by the individual and OFAC determined that the conduct constituted an egregious case.
To settle the charges, the individual agreed to pay $133,860.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
