It’s that time of the month again. The United States Department of Treasury Office of Foreign Assets Control (“OFAC”) has released their monthly bulletin highlighting the civil penalities that they have issued in the past 30 days.

While this month OFAC has only penalized 3 persons (2 entities and 1 individual) the fines totaled nearly $450,000, including a whopping $426,486.00 fine against Stena Bulk LLC, for allegedly violating the Sudanese Sanctions Regulations. OFAC accuses Stena Bulk of shipping oil to Sudan and exporting Sudanese oil from Sudan on behalf of a number of foreign entities without an OFAC license. What’s more interesting, perhaps, is that OFAC decided to issue the hefty fine after Stena Bulk had voluntarily disclosed their failure to comply.

Vonberg Valves, Inc. was also fined by OFAC to the tune of $11,049.50 for the illegal exportation of goods to Iran without an OFAC license under the Iranian Transactions Regulations. Vonberg Valves did not voluntarily disclose their violation to OFAC, but have since devised a U.S. sanctions compliance program.

According to a charging letter issued by the United States Department of Commerce Bureau of Industry and Security (“BIS”), Vonberg Valves attempted to export Flow Regulators and Flow Limiters through Germany to Iran without an OFAC License knowing that this constituted a violation of United States law. Furthermore, BIS alleges that one of their agents informed a Vonberg Valves sales representative of the sanctions program against Iran and that Vonberg Valves was informed by the shipping company that the parts were destined for Iran. BIS originally penalized Vonberg Vavle $21,000 for these violations.

In addition, to the above referenced entities, one individual was also fined by OFAC. An individual who allegedly supplied financial services to Burma by wiring money for payment of goods, was fined $4,206.00. This penalty should serve as another reminder to people engaging in online shopping, or those entities facilitating online financial transactions, that those transactions may result in an OFAC penalty being issued.

Click the following link for a copy of this month’s OFAC Civil Penalities Information.

Click the following link for a copy of the BIS Documents Related to Vonberg Valves, Inc.

If you feel that you may have violated any U.S. sanctions regulations please contact the author by email at info@ferrari-legal.com

The author of this blog is Erich C. Ferrari, an attorney in Washington, DC, who specializes in Sanctions Law and White Collar Criminal Defense. If you have any questions please email him at info@ferrari-legal.com