Sixteen orders of marine attenna systems were shipped to South Korea between 2007 and 2009, with the knowledge that they would be reexported to Iran. The value of the shipments was $387,281 and the base penalty amount for the violations, which were non-egregious and were voluntarily self-disclosed, was $189,141.
Here's the breakdown of the aggravating and mitigating factors that dropped the final civil monetary policy by more than 50%:
- This is Sea Tel’s “first violation,” given that OFAC has not issued any
penalty notice or Finding of Violation to Sea Tel in the five years preceding these transactions;- At
the time of at least six of the apparent violations, Sea Tel had an OFAC compliance program in
place;- Sea Tel has undertaken some remedial steps to prevent a recurrence of the apparent
violations;- Sea Tel provided some cooperation to OFAC, including by entering into agreements
to toll the statute of limitations;- Sea Tel’s provision of 16 antenna systems worth $378,281 to its
distributor for installation and use on vessels owned by the National Iranian Tanker Company
(“NITC”), an Iranian entity, caused harm to sanctions program objectives;- Sea Tel showed
reckless disregard for U.S. sanctions by shipping goods for reexport to NITC without adequate
due diligence;- Sea Tel’s reckless conduct constituted a pattern, providing antenna systems on 16
occasions over 15 months;- A Sea Tel sales manager had reason to know that the antenna systems
were destined for NITC and authorized the shipments; and- Sea Tel is a sophisticated
international business that should have had more than just general policies and procedures in
place to ensure OFAC compliance, including appropriate mechanisms to determine the location
of, and other information related to, the ultimate purchasers or users of its products.
Link:
Posted with BlogsyFiled under: Iranian Sanctions, OFAC Updates, Settlements
