Indonesian company to pay $1 million to settle violations of North Korea sanctions regulations

Indonesian company to pay $1 million

The Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department today announced that an Indonesian company agreed to pay slightly over $1 million to settle its potential civil liability for 28 apparent violations of the North Korea sanctions regulations.

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According to the OFAC release [PDF 115 KB], the Indonesian company—a paper products manufacturer—exported cigarette paper to entities located in or doing business on behalf of North Korea, and then directed payments for these exports to its “U.S. dollar” bank account at a non-U.S. bank, which in turn caused U.S. banks to clear wire transfers related to these shipments made to a blocked North Korean person.

The Indonesian company initially referenced North Korean entities on its transactional documents, but at the request of its customers, later replaced these references with the names of intermediaries located in third countries on the invoices, packing lists, and bills of lading. The commercial value of the Indonesian company’s exports to North Korea was approximately $960,000.

The Indonesian company actions caused 28 wire transfers to clear through U.S. banks between March 2016 and May 2018, in violation of the North Korea sanctions regulations. After learning of its exposure to U.S. sanctions laws and regulations, the Indonesian company represented that it ceased all dealings involving North Korea and adopted a formal written sanctions policy and compliance procedures.

OFAC determined that the Indonesian manufacturer did not voluntarily self-disclose these apparent violations, and that these apparent violations constitute a non-egregious case.


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