U.S. company settles sanctions violations | KPMG | GLOBAL
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U.S. company settles sanctions violations for $6 million

U.S. company settles sanctions violations

U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) today issued a release, reporting that a Delaware corporation and its subsidiaries agreed to pay almost $6 million to settle potential civil liability for apparent violations of the Iranian, Cuban, and Sudanese sanctions.


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According to the OFAC release [PDF 12 KB], from 2002 to 2009, the company engaged in certain conduct in apparent violation of the Iranian, Cuban, and Sudanese sanctions by: 

  • Approving commission payments to a UK-based entity, related to the sale and export of goods to Iran and engaging in transactions involving the sale and export of goods to Iran
  • Engaging in almost 50 transactions involving the sale of goods or services to Cuba 
  • Engaging in a transaction involving the export of goods to Sudan

OFAC stated that the U.S. corporation did not voluntary self-disclose the apparent violations and that the violations were “egregious because senior-level finance executives . . . approved the …payments,” the company “willfully blinded itself” in acquiescing to deliberate non-identification of Iran in certain communications, that the company had reason to know that the commission payments involved Iran, and that the company ignored several warning signs over the course of three years that approving the commission payments was prohibited conduct. 


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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