A U.S. shipping company agreed to pay a $518,063 penalty to settle potential liability concerning alleged violations of the Iranian Transactions and Sanctions Regulations.
The U.S. Treasury Department Office of Foreign Assets Control ("OFAC") determined that the California-based American Export Lines and International Shipping Company ("AEL") had violated OFAC regulations by "transshipping used and junked cars and parts from the United States via Iran to Afghanistan on 140 occasions." In addition, OFAC said, AEL failed to self-disclose the alleged violations. OFAC concluded that in connection with the apparent violations, (i) AEL did not exercise requisite caution in transshipping goods through Iran, (ii) the AEL president and co-owner approved the shipments through Iran, and (iii) AEL provided "economic benefit" to Iran through its transshipping activities.
Notwithstanding AEL's failure to self-disclose, OFAC characterized the misconduct as "non-egregious," and noted that the firm's compliance program, remedial actions, full cooperation and lack of prior sanctions, among other factors, were mitigating elements that contributed to the determination of the settlement amount.