Last week, the Office of Foreign Assets Control (“OFAC”) designated Singapore-based Senat Shipping Limited for providing support to a previously designated North Korean shipping company, Ocean Maritime Management Company (OMMC). According to press reports, Senat was responsible for chartering the container ship Chong Chon Gan, which was seized in Panama in 2013 with a cargo hold full of illicit arms, including two MiG-21 jet fighters. Following its designation, the company and its president Leonard Lai denied all involvement, likening the situation to “hiring a car and being held responsible for the car owner’s illegal activity.”

Perhaps there is some merit to Senat’s protestations, perhaps not. But it surely did not help their case that the company failed to respond to inquiries from the United Nations Panel of Experts Established Pursuant to Resolution 1874. It also apparently did not respond to questions from the authorities in Singapore.

The company must have been under impression that they had some sort of protection against self-incrimination under U.S. sanctions law. Unfortunately for them, nothing in the International Emergency Economic Powers Act or Executive Order (E.O.) 13551 grants that protection. Under the “reasonable cause to believe” standard applied by OFAC in designation cases, failure to respond to inquiries regarding possible violations could very well be considered incriminating.

So if you receive an inquiry from any investigative body regarding potential sanctions violations, whatever you do, don’t just ignore it.