The United States Department of Treasury Office of Foreign Assets Control (“OFAC”) released its monthly report of civil penalties. Some big names and big numbers this month, including Philips Electronics of North America which was fined $128,750.00 for violations of the Cuban Assets Regulations.

While Philips was perhaps this month’s most recognized entity to be fined, it was not the recipient of the largest penalty. That dubious honor goes to Oxbow Carbon and Minerals LLC, which was fined a whopping $276,250.00 for violations of the Iranian Transactions Regulations (“ITR”). Apparently, Oxbow Carbon and Minerals was involved in transactions that utilized the vessels of the Islamic Republic of Iran Shipping Lines. This of course is a big no no under the ITR and Oxbow Carbon and Minerals was fined accordingly. Although, they did not voluntarily disclose the violations, they cooperated with OFAC’s review and furthermore, made changes to their OFAC compliance program to prevent similar transactions from occurring in the future.

Other penalties were handed down to National Marine Consultants, Inc. for $42,075.00 for violations of the ITR and Willbros United States Holdings, Inc. who were penalized $6,600 for violations of the Sudanese Sanctions Regulations.