The Office of Foreign Asset Control of the US Department of the Treasury has entered into an agreement with Park Strategies, LLC, to settle the New York lobbying firm’s potential civil liability for apparent violations of the Global Terrorism Sanctions Regulations, 31 CFR, part 594. According to OFAC, Park Strategies appears to have violated 31 CFR § 594.201 when it entered into a contract with Al Barakaat Group of Companies Somalia Limited, a Specially Designated Global Terrorist (SDGT), for the provision of lobbying services.
According to OFAC, Park Strategies executives knew of Al-Barakaat’s designation when they signed the lobbying contract in August 2017. OFAC found, however, that Park Strategies voluntarily disclosed the apparent violations after receiving the first of three scheduled payments under the contract. Park Strategies directed its bank to place the payment into a blocked account, notified OFAC, suspended performance under the contract, and instructed its external counsel to begin an investigation.
The maximum statutory civil monetary penalty in this matter is $302,584. In determining the settlement amount of $12,150, OFAC took into consideration both aggravating factors such as Park Strategies’ executives’ actual knowledge of Al-Barakaat’s GDGT status, and mitigating factors such as the remedial measures taken by Park Strategies, and the firm’s violation-free record in the preceding five years. These factors, pursuant to OFAC’s Economic Sanctions Enforcement Guidelines, resulted in a base civil monetary penalty of $15,000, or half of the $30,000 contract value.
US Dept of the Treasury press release | OFAC Enforcement Information