Since the start of September, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) has settled with two different companies for alleged violations of U.S. economic sanctions on Iran. The settlements, the first with World Class Technology Corporation (WCT) and the second with PanAmerican Seed Company (PanAmerican), yielded vastly different outcomes. As summarized below, we think the divergent results serve to illustrate how OFAC weighs various factors in calculating penalty amounts.
WCT. On September 7, 2016, OFAC settled with WCT for $43,200 based on alleged violations of the Iranian Transactions and Sanctions Regulations (ITSR). The alleged violations occurred when WCT exported seven shipments of orthodontic devices to Germany, Lebanon and the United Arab Emirates with suspicion that the devices would be exported to Iran. The devices were collectively valued at almost $60,000. The exports occurred between April 2008 and July 2010.
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