California cosmetics company settles possible North Korea sanctions violations

The Office of Foreign Assets Control of the US Department of the Treasury has announced a settlement with e.l.f. Cosmetics, Inc., a cosmetics company with headquarters in California, to resolve possible violations of 31 C.F.R. part 510 of the North Korea Sanctions Regime.  OFAC alleges that between April 2012 and January 2017, e.l.f. imported 156 shipments of false eyelash kits that contained materials sourced from the Democratic People’s Republic of Korea. The company voluntarily disclosed the apparent violations, and received credit for other mitigating factors such as a clean record for the five preceding years, the company’s full cooperation with OFAC once the violations had been disclosed, the limited significance of the business involved in the violations, and the fact that e.l.f. employees had no actual knowledge of the violations.  The primary aggravating factor was the inadequacy or non-existence of an OFAC compliance program.  In addition to paying a civil penalty of $996,080, e.l.f. has taken measures to prevent future violations, including the adoption of new compliance procedures for suppliers, enhanced supplier audits and supply chain audits, and mandatory sanctions training for employees.

OFAC Enforcement Information