Six violations of anti-narcotics trafficking sanctions were the cause. The violations:
From on or about October 9, 2009, to onor about July 21 , 2010, Campofresco made six purchases worth a total of$344,016 of frozenpassion fruit juice/pulp from Frutas Exoticas Colombiana S.A. (a.k.a. Frexco S.A. d/b/a GrupoC. Lozano Frexco SAS), a Specially Designated Narcotics Trafficker.
The violations, while not voluntarily self-disclosed, were non-egregious in nature, resulting in a base penalty of $600,000. Here's why the fine got knocked down so much:
OFAC considered the following to be mitigating factors:
- Campofrescohas not received a penalty notice or Finding ofViolation from OFAC in the five years precedingthe date of the earliest transaction giving rise to the apparent violations;
- Campofresco cooperatedwith OFAC's investigation;
- Campofresco took appropriate remedial measures by instituting acompliance program in response to the apparent violations; and
- The individual characteristics ofthe company, including the size of its operations and financial condition.
OFAC found thefollowing to be an aggravating factor: Campofresco did not have an OFAC compliance programin place at the time of the apparent violations,.