International Trade Law News

Published by Jacobson Burton Kelley PLLC

On May 4, 2007, the Treasury Department's Office of Foreign Assets Control (OFAC) issued its monthly report of civil penalties imposed on companies and individuals for allegedly violating the sanctions regimes administered by OFAC.

OFAC's monthly report indicates that the agency settled five cases involving corporations and three cases against persons. The following is a summary of the settlements:

Entities:

• PSL Energy Services paid a civil penalty of $164,006.50 to settle allegations of violations of the Cuban Assets Control Regulations in 2004. PSL voluntarily disclosed to OFAC that it may have violated the Cuban Assets Control Regulations by engaging in the unlicensed exportation and re-exportation of oilfield servicing equipment and related skilled services to Cuba.
  

• Polek & Polek, a Fairfield, NJ distributor of imaging products, paid $3,350 to settle allegations of violations of the Iranian Transactions Regulations in 2004. OFAC alleged that Polek & Polek acted without an OFAC license or outside the scope of its license by exporting goods to Iran. Polek & Polek did not voluntarily disclose this matter to OFAC.

• Fleet National Bank on behalf of Suretrade, Inc. remitted $7,277 to settle allegations of violations of the Iranian Transactions Regulations in 2000. OFAC alleged that Suretrade acted without an OFAC license or outside the scope of its license by operating an account for a person located in Iran. This matter was not voluntary disclosed to OFAC.

• ACRA-CUT, Inc., an Acton, Massachusetts-based manufacturer of medical devices, paid $808 to settle allegations of violations of the Iranian Transactions Regulations occurring in February 2002. OFAC alleged that ACRA-CUT acted without an OFAC license by exporting goods to Iran. ACRA-CUT did not voluntarily disclose this matter to OFAC.

• Turkish Airlines was assessed a $2,226.24 civil monetary penalty for its violation of the Iranian Transactions Regulations occurring on July 28, 2004. OFAC imposed the penalty because of Turkish Airlines’ involvement in the transportation of photocopy machine parts to an individual located in Iran. Turkish Airlines did not voluntarily disclose this matter to OFAC. In an unusual move, OFAC provided the URL of OFAC’s penalty notice issued to Turkish Airlines, which shows that the airline did not respond to the agency's prepenalty notice.
  

• An individual agreed to pay $485 for allegedly engaging in transactions with an entity previously identified as a Specially Designated Narcotics Trafficker (SDNT). OFAC alleged that the individual made payments by cash and credit card to the SDNT for rent involving the use of a trailer. The individual did not voluntarily disclose this matter to OFAC.

• One individual has agreed to pay $6,088.85 to settle charges of allegedly dealing in property in which Cuba or a Cuban national had an interest. Specifically, OFAC alleged that the individual purchased Cuban-origin cigars offered for sale on the Internet. The person did not voluntarily disclose this matter to OFAC, however the person later provided information to OFAC concerning additional purchases of Cuban-origin cigars.

• Another individual has agreed to a settlement totaling $1,261.00 for purchasing Cuban-origin cigars offered for sale on the Internet. The individual did not voluntarily disclose this matter to OFAC.

Labels: OFAC, Sanctions, Sanctions; Iran