International Trade Law News

Published by Jacobson Burton Kelley PLLC

The Treasury Department's Office of Foreign Assets Control (OFAC) today issued its June 2009 (pdf) monthly report of civil penalties imposed for alleged violations of the sanctions regimes administered by OFAC.

OFAC announced the following four settlements with companies, none of which were resolved under OFAC's new enforcement guidelines implementing the enhanced maximum civil penalties of $250,000 for IEEPA-based violations:

• Oxbow Carbon and Minerals LLC of West Palm Beach, Florida agreed to remit $276,250.00 to settle allegations that if violated te Iranian Transactions Regulations in 2006 and 2007. OFAC alleged that Oxbow engaged in transactions in or related to services of Iranian origin and facilitated trade-related transactions by non-U.S. persons which involved the use of vessels owned and/or managed by the Islamic Republic of Iran Shipping Lines in Tehran, Iran, without an OFAC license. While Oxbow did not voluntarily disclose the alleged violations, OFAC noted that the company demonstrated cooperation during OFAC’s review of the matter and as a remedial measure has made revisions to its compliance program.
  

• National Marine Consultants, Inc. remitted $42,075.00 to settle allegations of violations of the Iranian Transactions Regulations that occurred between March 2005 and May 2007. OFAC alleged that NMCI outsourced to an Iranian entity inspection services it was contractually bound to perform for a third-party, without an OFAC license. NMCI did not voluntarily disclose the matter to OFAC but cooperated with OFAC’s investigation.

• Philips Electronics of North America Corporation (PENAC) remitted $128,750.00 to settle allegations that it violated the Cuban Assets Control Regulations between 2004 and 2006. OFAC alleged that PENAC acted without an OFAC license through an employee’s travel to Cuba in connection with the sale of medical equipment by a foreign affiliate of PENAC. PENAC voluntarily disclosed this matter to OFAC.
  

• Houston, Texas-based Willbros USA, Inc. paid $6,600 to settle an allegation of violation of the Sudanese Sanctions Regulations occurring in 2003 and 2004. OFAC alleged that Willbros, through a former Senior Vice President, willfully violated the Sudanese Sanctions Regulations (SSR) when it entered into a contract to bid on an oil development project in Sudan, despite its knowledge that such activities violated the Regulations, by facilitating the export of goods, technology or services to Sudan and evading the prohibitions set forth in the SSR. Willbros voluntarily disclosed this matter to OFAC.

Labels: Cuba, OFAC, Sanctions; Iran, Sanctions; Sudan