ENFORCEMENT INFORMATION FOR September 30, 2009
Barwil Agencies NA, Inc. Settles Allegations of Violations of the Iranian Transactions Regulations: Barwil Agencies NA, Inc. ("Barwil"), of Pasadena, TX has agreed to remit $84,000.00 to settle allegations of violations of the Iranian Transactions Regulations occurring on or about January 2007. OFAC alleged that Barwil engaged in transactions in or related to services of Iranian origin and facilitated trade-related transactions by non-U.S. persons which involved the payment of port expenses for a vessel’s port call in the Iranian port of Bandar Mahshahr, without an OFAC license. Barwil did not voluntarily disclose the alleged violations to OFAC. The company demonstrated cooperation during OFAC’s review of the matter and as a remedial measure has made revisions to its compliance program. This matter was resolved according to the prior enforcement guidelines published by OFAC at 68 Fed. Reg. 4422.
1) Fined entity was is U.S. sub of Norwegian company.
2) Here it appears that the U.S. person was involved in payment of port expenses in connection with a vessel and underlying transaction that otherwise had nothing to do with the U.S. This would be ordinary facilitation in most IEEPA-based embargoes (560.208), but here is also a direct violation of 560.206, which prohibits all transactions related to "Iranian origin services," incl. port services. Compare Civil Enforcement Information - Norton Lilly International (2011).