Enforcement Release - Pegasus Worldwide Logistics

Date issued: Oct. 09 2026

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TURBOFAC Commentary (237 words)

Notes:

1) Enforcement action straightforward in terms of legal basis for the penalties (dealings related to the importation of property in which a blocked person has an interest), but notable in terms of diligence expectations conveyed, especially as it relates to “reason to know”. Pegasus has “it had reason to know [it was dealing with ] the same party OFAC had sanctioned” based in part on Pegasus having “instructed Youli—via communication with an email address identified as associated with Youli on the SDN List—to arrange with a Chinese shipping agent for the machine to be shipped to the United States,” and “[t]he Chinese shipping agent [having] prepared the necessary shipping documents from China and sent them to Pegasus…[which] included Youli’s unchanged telephone number as OFAC identified it on the SDN List.” The implication appears to be that at all points along the...