OFAC settles apparent Foreign Narcotics Kingpin Sanctions violations with Maryland trade credit and collections company
In determining the settlement amount of $345,315, OFAC considered as aggravating factors Atradius’ failure to make a voluntary self-disclosure of the apparent violations, its failure to seek confirmation from OFAC that assignment of the SDN’s debt was permissible, and Atradius’ status as a subsidiary of a sophisticated global trade credit and collections conglomerate, Atradius N.V. OFAC also took into consideration several mitigating factors, such as the company’s clean record for the five years preceding the subject transactions, and its willingness to conduct a comprehensive internal review, take voluntary remedial action, and provide documents to OFAC during the investigation.
OFAC pointed out in its announcement of the settlement, that the enforcement action against Atradius highlights the importance of obtaining a specific license before engaging in otherwise unauthorized activity involving an SDN’s debt.