International Trade Law News

Published by Jacobson Burton Kelley PLLC

The Treasury Department's Office of Foreign Assets Control (OFAC) recently issued its September 2008 (pdf) monthly report of civil penalties imposed on companies and individuals for allegedly violating the sanctions regimes administered by OFAC.

Companies - OFAC announced the following five settlements with companies:

• Agoda Company, Pte Ltd. of Bangkok, Thailand which is owned or controlled by persons subject to U.S. jurisdiction, remitted $6,750.00 to settle allegations of 50 violations of the Cuban Assets Control Regulations occurring between in 2006 and 2007. OFAC alleged that Agoda provided travel-related services in which Cuba or Cuban nationals had an interest by arranging hotel reservations in Cuba without an OFAC license. Agoda cooperated with OFAC’s investigation and has implemented corrective measures and improvements to its OFAC compliance program. Agoda voluntarily disclosed this matter to OFAC.

• Como Design, Inc. paid $5,980.03 to settle allegations of violations of the Narcotics Trafficking Sanctions Regulations occurring in 2005. OFAC alleged that Como acted without an OFAC license by receiving and depositing checks issued by an OFAC Specially Designated Narcotics Trafficker. Como did not voluntarily disclose this matter to OFAC.

• LI-COR, Inc. of Lincoln, NE remitted $2,315.02 to settle allegations of violations of the Iranian Transactions Regulations. OFAC alleged LI-COR attempted to send a funds transfer to Gulf Biosystems Trading LLC’s Bank Saderat account without an OFAC license. LI-COR did not voluntarily disclose this matter to OFAC but has instituted a comprehensive U.S. sanctions compliance program.

• Tabletops Unlimited, Inc. of Carson, CA paid $1,000 to settle an allegation of a violation of the Iranian Transactions Regulations. OFAC alleged that on or about October 11, 2005, Tabletops attempted to send a funds transfer to the Bank Melli account of a company located in Tehran, Iran for purposes of purchasing and importing Iranian-origin goods into the United States without an OFAC license. Tabletops did not voluntarily disclose this matter to OFAC.

• Ritz Camera Centers, Inc., Beltsville, MD remitted $500 to settle allegations of violations of the Burmese Sanctions Regulations occurring in July 2006. OFAC alleged that Ritz Camera attempted to send a $1,000 funds transfer to an account holder at Myanmar Foreign Trade Bank. Ritz Camera did not voluntarily disclose this matter to OFAC.

Individuals - OFAC settled 2 cases involving individuals (OFAC does not release the names of individuals involved in civil penalty cases):

• OFAC settled two cases involving the purchase of Cuban-origin cigars offered for sale on the Internet. In one case, an individual agreed to a settlement totaling $6,056.50 for purchasing Cuban cigars on the Internet on at least 16 occasions. This is one of the largest civil penalties imposed on an individual relating to the purchase of Cuban cigars. In another case, one paid $500 to settle allegations stemming from the purchase of Cuban cigars on the Internet in January and April 2005. Neither of these cases were voluntarily disclosed.

Labels: OFAC