On August 8, 2019, the Office of Foreign Assets Control of the US Department of the Treasury issued a finding of violation to DNI Express Shipping Company, located in McLean, Virginia, for a violation of 31 CFR § 501.602. According to the Enforcement Information, after receiving an administrative subpoena in May 2015 to investigate its involvement in the shipment, supply and sale of farm equipment to Sudan in apparent violation of the Sudanese Sanctions Regulations then in effect, DNI provided contradictory, false, materially inaccurate, incomplete and misleading statements to OFAC.
In deciding to issue a finding of violation to DNI, OFAC considered that DNI’s reckless disregard for US sanctions requirements, its financing and shipment of goods to Sudan, its false and misleading responses to OFAC despite having actual knowledge that the information provided was inaccurate and incomplete, and its failure to amend its responses when given the opportunity to do so, constituted a failure to cooperate fully with OFAC’s investigation. DNI’s small size and clean history were deemed to be mitigating factors, along with the fact that DNI’s narrative responses were apparently filtered through outside counsel.