Trading Company Settles OFAC Sanctions Violations for Concealing Transactions Involving Iran

A Thai-based trading company settled OFAC sanctions violations for concealing, from U.S. financial institutions, the sale of products made in Iran.

According to the Settlement Agreement, the company regularly received U.S. payments for sales of Iranian produced products. OFAC said that the company received payments by employing documentation practices that hid the fact the product was made in Iran, thereby evading detection by U.S. correspondent banks that processed the transactions. OFAC found the company routinely sent final commercial invoices to its customers that listed the shipment as being from Jebel Ali, UAE.

OFAC also found that in instances where the company paid off debts owed by the manufacturer in U.S. dollars, the company failed to provide information to the financial institutions involved in the transactions indicating the payments were on behalf of the manufacturer. OFAC said the payment instructions provided by the company misleadingly stated the payments were for "payment for goods," even though the company had not purchased goods from these vendors.

To settle the charges, the company agreed not to engage in further business activities (through liquidation,) and to pay $20,000,000. The amount reflected OFAC's determination that the company's apparent violations were egregious and, with the exception of certain transactions, were not voluntarily self-disclosed.