Between March 2008 and February 2011, the firm took part in transactions supplying wireless broadband equipment to Iran (through distributors in the United Arab Emirates and Greece). The base penalty was $560,240.
Why such a small discount?
- Ubiquiti demonstrated reckless disregard for U.S. sanction
requirements; - Ubiquiti was on notice in February 2010 that the conduct at issue constituted a
violation of U.S. law; - members of Ubiquiti’s senior management knew or had reason to know
that Ubiquiti products were reexported to Iran; - Ubiquiti’s conduct resulted in the provision of
goods related to broadband wireless connectivity, worth at least $588,938, to entities located in
Iran; - Ubiquiti engaged in a pattern of conduct over five years that resulted in several apparent
violations during that period; - Ubiquiti had no OFAC compliance program in place at the time of
the apparent violations; - Ubiquiti has no prior sanctions history, including not being the subject of
a penalty notice or Finding of Violation; - Ubiquiti cooperated with OFAC during its investigation of the apparent violations; and
- Ubiquiti took remedial action in response to the apparent
violations.
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Posted with BlogsyFiled under: Iranian Sanctions, OFAC Updates, Settlements
