In the fine print: Life for Relief and Development fined $780,000 by OFAC

Literally in a footnote to the March 25th announcement of the enforcement action against PayPal, OFAC also released enforcment information about a $780,000 penalty against Life for Relief and Development. The base penalty for “knowingly and willingly” conspiring to send 3 funds transfers totaling $236,000 to Iraq in violation of those sanctions was $1,300,000.

Here’s OFAC’s calculus:

LRD appears to have willfully violated U.S. economic sanctions
regulations; prior to the relevant transactions,

LRD had written notice from OFAC that such
transfers were prohibited and that OFAC did not authorize such transactions;

LRD’s highest
management levels—i.e., its President—knew of the conduct giving rise to the apparent
violations and directed the funds transfers to Iraq via Jordan;

U.S. economic sanctions program
objectives were harmed because funds were successfully transferred to Iraq;

LRD does not have
prior OFAC sanctions history, including receipt of a penalty notice or Finding of Violation
during the five years preceding the date of the earliest transaction giving rise to the apparent
violations;

LRD undertook a remedial response to the transactions and agreed to establish an
OFAC compliance program;

LRD cooperated by waiving the statute of limitations regarding the
apparent violations; and

the civil settlement with OFAC is an element of LRD’s cooperation
agreement with the U.S. Department of Justice.