On Friday, OFAC buried a small enforcement action behind a couple of mouse clicks (like it did with Dal-Tech and Bank Tokyo Mitsubishi UFJ).
This one was for violation of the Iranian Transaction Regulations and Executive Order 13382, which are the WMD sanctions regulations. Offshore Marine Laboratories shipped parts to the UAE for an oil rig in Iranian waters. Base penalty: $167K. Final civil penalty: $97.695
I always wonder why they have such odd amounts and don’t just round the figures….
This one was not voluntarily self-disclosed, but wasn’t consider egregious. Here’s the skinny from OFAC as to why the fine landed where it did:
OML harmed sanctions program objectives because the transactions aided the development of Iranian petroleum resources; OML had no OFAC compliance program in place at the time of the alleged violations; OML has no history of prior OFAC violations; OML demonstrated substantial cooperation with OFAC throughout the investigation, including entering into a statute of limitations tolling agreement; and OML took remedial measures by implementing an OFAC compliance program.
Mr. Watchlist wonders what makes this non-egregious. Maybe because it was very limited in scope – a single type of transaction conducted with a single counterparty (over the span of about a year). Clearly it pales in comparison to the recent large penalties where there was a more general failing.
What is also interesting is that the counterparty was in the UAE – a firm such as OML needs to drill down when it engages in sales transactions as to the ultimate destination and use of its products, and can’t rely on the name and location of the immediate counterparty. It’s kind of similar to Transocean’s slip-ups regarding leasing a drilling rig for waters off the coast of Burma – controlled by someone on the SDN list.