Well, after a month of heavy settlements the United States Department of Treasury Office of Foreign Assets Control (“OFAC”) issued their monthly civil penalties and to my surprise there was only one settlement. That settlement came against Thermon Manufacturing Company (“Thermon”). Thermon paid $14,613.24 to settle allegations that they violated the Sudanese Sanctions Regulations. According to the release, Thermon, engaged in and facilitated the export and re-export of heat tracing equipment in three seperate transactions.

The Sudanese Sanctions Regulations prohibit U.S. persons from engaging in transactions with Sudan without a specific license from OFAC. This includes the act of facilitation which includes but is not limited to, brokering activities, exportation, or re-exportation. Violators of these prohbitions face stiff fines and even criminal penalties.

Portions of the Sudanese Sanctions regulations do not prohibit transactions with the Government of Southern Sudan. However, before you go and try to conduct transactions with individuals or entities you assume are part of the Government of Southern Sudan, please check the regulations and make sure you are complying with the sanctions.