U.S. company to pay $189,000 to settle violations of Iranian sanctions

Potential civil liability for apparent violations of the Iranian transactions and sanctions regulations

U.S. company to pay $189,000

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) today announced that a U.S. company has agreed to pay approximately $189,000 to settle its potential civil liability for apparent violations of the Iranian transactions and sanctions regulations.

According to today’s OFAC release [PDF 195 KB], the apparent violations occurred when the company—headquartered in San Antonio, Texas, that develops and supplies live production and 3D animation hardware and software systems—exported goods, technology, and services from the United States to third-country distributors that it knew or had reason to know were specifically intended for companies and individuals in Iran.

The total value of the transactions constituting the apparent violations was approximately $580,00, and the profits associated with the sales of the products that constituted the violations amounted to approximately $61,000.

The company did not have export control or sanctions compliance policies or procedures in place during the relevant time period and did not provide training to personnel regarding export control or sanctions compliance. The company incorrectly believed that its product sales through third-party distributors to the Iranian reseller were in accordance with applicable sanctions regulations in part because the company did not deal directly with Iran, but rather through a third-country intermediary.

The settlement amount reflects OFAC’s determination that the company’s conduct was non-egregious and voluntarily self-disclosed, and accounts for the company’s remedial response and cooperation with OFAC during the investigation. 
 

For more information on this topic or to learn more about KPMG’s Trade & Customs Services, contact:

Doug Zuvich
Partner and Global Practice Leader
T: 312-665-1022
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
T: 267-256-2614
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
T: 631-425-6057
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
T: 415-963-7861
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
T: 212-954-3094
E: labad@kpmg.com

Irina Vaysfeld
Principal
T: 212-872-2973
E: ivaysfeld@kpmg.com

Amie Ahanchian
Principal
T: 202-533-3247
E: aahanchian@kpmg.com

Christopher Young
Principal
T: 312-665-3229
E: christopheryoung@kpmg.com

Gisele Belotto
Managing Director
T: 305-913-2779
E: gbelotto@kpmg.com

George Zaharatos
Principal
T: 404-222-3292
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
T: 313-230-3080
E: adoornaert@kpmg.com

Jessica Libby
Managing Director
T: 612-305-5533
E: jlibby@kpmg.com

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