U.S. luxury goods retailer | KPMG | US

U.S. luxury goods retailer settles narcotics kingpin sanctions violations

U.S. luxury goods retailer

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) today announced that a luxury goods company headquartered in New York agreed to pay almost $335,000 to settle its potential civil liability for four apparent violations of the “Foreign Narcotics Kingpin Sanctions Regulations.”

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The OFAC release [PDF 145 KB] provides that:

  • On four separate occasions, an individual purchased jewelry from one of the company’s boutiques (in California and Nevada) and provided the name of an entity that was on the “specially designated nationals and blocked persons” (SDN) list as the name and mailing address of the ship-to party. 
  • The company did not identify any sanctions-related issues prior to shipping the goods. 
  • The company exported four shipments of jewelry to the entity on the SDN list.
  • The company did not voluntarily self-disclose the apparent violations.
  • The OFAC found aggravating factors, such as the company failed to exercise a minimal degree of caution or care with respect to the conduct that led to the apparent violations, caused significant harm to the objectives of U.S. sanctions regulations by dealing in the property of an SDN and by allowing an SDN access to the commercial marketplace; and was a commercially sophisticated entity with global operations operating in an industry at high risk for money laundering. 

 

For more information, contact a professional with KPMG’s Trade & Customs practice:

Douglas Zuvich | +1 (312) 665-1022 | dzuvich@kpmg.com

Andrew Siciliano | +1 (631) 425-6057 | asiciliano@kpmg.com

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