OFAC Enforcement Action: $43,200 CMP for World Class Technology Corp.

The firm committed 7 apparent violations of the Iranian Transaction Sanctions Regulations (ITSR) when it shipped orthodontic devices that ended up in Iran. The value of the devices was $59.886, and the base penalty for the non voluntarily self-disclosed, non-egregious violations was $80,000 (statutory maximum was $1,750,000).

Here’s why the find got knocked down almost 50%:


OFAC considered the following to be aggravating factors: 

  1. WCT willfully violated U.S. sanctions laws; 
  2. WCT’s management had actual knowledge or reason to know that WCT’s products were being exported to Iran; and 
  3. WCT had no OFAC compliance program in place until June 2008. 

OFAC considered the following to be mitigating factors: 

  1. the alleged violations did not result in great economic or other benefit conferred on Iran, as the transactions likely would have been licensed by OFAC had WCT applied for a license; 
  2. WCT has no sanctions history with OFAC for the five years preceding the date of the first transaction giving rise to the alleged violations; 
  3. WCT cooperated with OFAC by agreeing to toll the statute of limitations; 
  4. WCT developed an economic sanctions compliance procedure in June 2008 and subsequently drafted a written compliance policy; and 
  5. WCT lacked commercial sophistication in conducting international sales at the time of the alleged violations. 


OFAC Enforcement Information

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