A Hong Kong-based offshore trading and cross-border financing company settled potential civil liability for apparent violations of the Iranian Transactions and Sanctions Regulations ("ITSR").
According to OFAC, for nearly two years - from August 2016 through May 2018 - the company purchased high-density polyethylene resin of Iranian origin for resale to customers in China. Employees at the company - acting without the knowledge of executive management and in direct contravention of company policy - omitted Iranian country of origin information from transactional documents, causing the relevant payments to be processed by U.S. financial institutions. This conduct resulted in the company's apparent violation of ITSR section 203 ("Evasions; Attempts; Causing Violations; Conspiracies") by causing the U.S. financial institutions to violate ITSR sections 206 ("Prohibited Trade-Related Transactions with Iran; Goods, Technology, or Services") and 208 ("Prohibited Facilitation by United States Persons of Transactions by Foreign Persons").
OFAC found that the apparent violations constitute a non-egregious case, and that the company voluntarily self-disclosed the relevant conduct. To settle the charges, the company agreed to remit $5,228,298.
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