Individual settles potential civil liability for apparent ITSR violations

On December 8, 2021, the Office of Foreign Assets Control of the US Department of the Treasury announced a $133,860 settlement with an unnamed individual, resolving the US person’s potential civil liability for apparent violations of §§ 560.204, 560.206, and 560.208 of the Iranian Transactions and Sanctions Regulations (31 CFR Part 560).

According to OFAC, in February and March of 2016, four payments were transferred to the individual’s US bank account from a source outside of the United States, in payment for Iranian-origin cement products received by the payer from an Iranian cement company where the brother of the US individual worked.  Prior to the four payments, the individual had applied to OFAC and been denied a license authorizing other transactions with Iran.  OFAC notes in the enforcement release that its letter denying the license application provided details about the prohibitions involving Iran, and that the individual had received communications from the Iranian company describing how US sanctions made it difficult to receive dollar payments.

In assessing a civil monetary penalty equal to the total value of the four payments, $133,860, OFAC viewed as aggravating factors the individual’s knowledge of and active participation in the apparent violations, the harm caused to the objectives of the ITSR, and the fact that the individual willfully or recklessly ignored US sanctions.  Other factors, such as the individual’s clean record in terms of findings of violations or cautionary letters from OFAC in the five preceding years, and the fact that the individual did not appear to benefit from the transaction, were deemed to mitigate the gravity of the apparent violations.

Enforcement release

 

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