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February 25, 2008 

OFAC Issues Monthly Penalty Report

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

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


  • Key Bank N.A., Cleveland, Ohio paid $200,000 to settle allegations of violations of the Iranian Transaction Regulations occurring between 2002 and August 2004. OFAC alleged that Key Bank acted without an OFAC license or outside the scope of its license by operating accounts for an entity and a person located in Iran. Key Bank did not voluntarily disclose this matter to OFAC.
  • BankAtlantic of Fort Lauderdale, Florida remitted $7,500 to settle allegations of possible violations of the Cuban Assets Control Regulations occurring in July 2004. OFAC alleged that BankAtlantic failed to block a payment in which the Government of Cuba had an interest. OFAC noted that BankAtlantic Bank voluntarily disclosed this matter, cooperated in the investigation and has implemented corrective measures and improvements to its OFAC compliance program.
  • Buehler Ltd., a Lake Bluff, Illinois manufacturer of scientific equipment and supplies for use in materials analysis, has remitted $20,000 to settle allegations of violations of the Iranian Transactions Regulations occurring between September 2002 and November 2003. OFAC alleged that Buehler acted without an OFAC license or outside the scope of its license by exporting technological equipment to entities in Iran. OFAC indicated that Buehler did not voluntarily disclose the matter to OFAC, but cooperated in the investigation.
  • La Salle Bank Midwest, N.A. of Chicago, Illinois remitted $5,500 on behalf of its affiliate Standard Federal Bank to settle allegations of violations of the Iranian Transactions Regulations occurring February 2002. OFAC alleged that Standard Bank acted without an OFAC license or outside the scope of its license by initiating a funds transfers destined for a bank owned or controlled by the Government of Iran. Standard Bank did not voluntarily disclose this matter to OFAC.
  • OFAC imposed a $941 civil penalty on RMO, Inc., a Denver, Colorado based manufacturer of orthodontic equipment, for violating the Cuban Assets Control Regulations. OFAC alleged that in June 2005 RMO, Inc. dealt in property in which a Cuba or a Cuban national had an interest by initiating a funds transfer involving travel to Cuba. OFAC originally proposed a $1,711 penalty on RMO, but the penalty amount was reduced after the company advised OFAC that the employee responsible for the violation was terminated , the company is instituting a compliance program for its employees and that this was RMO's first offense. RMO, Inc. did not voluntarily disclose this matter to OFAC.
Persons (OFAC does not release the names of individuals involved in civil penalty cases):
  • OFAC settled five cases involving the purchase of Cuban-cigars offered for sale on the internet for amounts ranging from $456 to $5,213. The average settlement amount was $1,848.
  • OFAC also settled a case for $1,000 against an individual for travel-related transactions incident to Travel with Cuba that involved the receipt of and payment for goods and services. According to OFAC, the individual traveled to and from Cuba via third countries.

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