OFAC - Enforcement actions for violations of trade sanctions 

September 10: The Treasury Department’s Office of Foreign Assets Control (OFAC) issued reports of resolution of violations of U.S. trade sanction provisions.
  • According to a September 9 release [PDF 11 KB], a Miami-based fuel company agreed to pay approximately $40,000 to settle alleged violations of the Iranian Transactions Regulations (ITR), the Sudanese Sanctions Regulations (SSR), and the Cuban Assets Control Regulations (CACR) for (1) the facilitation of a sale by one of its non-U.S. affiliates of fuel for a vessel at port in Bandar Abbas, Iran; (2) the facilitation by a U.S. subsidiary of services and fuel purchases for an aircraft that stopped in Khartoum, Sudan; and (3) coordination services provided by two U.S. subsidiaries for 30 unlicensed flights to Cuba. The OFAC determined that the company self-disclosed the alleged violations of the ITR and SSR, but did not voluntarily self-disclose the alleged violations of the CACR, and that all of the alleged violations constitute a non-egregious case.


  • According to a September 6 release [PDF 17 KB], a Palo Alto-based company agreed to pay approximately $350,000 to settle alleged violations of the Iranian Transactions Regulations involving the sale, attempted sale, or shipment by foreign subsidiaries of x-ray generators, medical digital imaging workstations, and automatic exposure control field kits to entities in Tehran, Iran, and Istanbul, Turkey. The OFAC determined that the company voluntarily self-disclosed the alleged violations and that the apparent violations constitute a non-egregious case.


  • According to a September 5 release [PDF 20 KB], a bank trust company agreed to remit approximately $19,000 to settle two alleged violations of Executive Order 13382 of June 28, 2005, “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters” concerning funds transfers to entities in Iran. The OFAC determined that the company did not voluntarily self-disclose the apparent violations and that the apparent violations constituted a non-egregious case.


For more information, contact a professional with KPMG’s Trade & Customs practice:


Douglas Zuvich

(312) 665-1022


Andrew Siciliano

(631) 425-6057


John L. McLoughlin

(267) 256-2614


Todd R. Smith

(949) 885-5617


Luis A. Abad

(212) 954-3094


Amie Ahanchian

(202) 533-3247


Or your local KPMG Trade & Customs professional.




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