According to OFAC, between April 2013 and February 2018, the company provided commercial services and software to airlines that had been sanctioned as specially designated global terrorists ("SDGTs"). OFAC found that the SDGTs - Mahan Air, Syrian Arab Airlines and Caspian Air - were also member-owners of the company. During OFAC's investigation, it determined that the company provided services to two additional SDGTs, Meraj Air and Al-Naser Airlines. OFAC explained that the services and technology offered to the SDGTs were subject to U.S. jurisdiction, since they were provided "from or through" the United States.
To settle the potential civil liability stemming from the case, the company agreed to pay $7,829,640. The settlement included, among other things, the firm's implementation of remedial measures, such as:
- establishing a global trade board and committee designed to monitor compliance risk;
- appointing a global head of ethics and compliance;
- creating enhanced sanctions legal compliance reviews when doing business with new customers and suppliers;
- conducting audits of messaging services to ensure that they are not being used by SDGT airlines; and
- requiring employees to complete annual sanctions compliance training.
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