OFAC Enforcement

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (854 words)

Notes:

1) The pre-penalty notice shows that OFAC "preliminary proposed" a penalty of $322,272,000. for 32,228 alleged recordkeeping violations (in connection with shipments that may or may not have been covered by licenses and exemptions). Recordkeeping violations, in which tens of thousands of violations can result from the same error, are a good way to be put in a situation in which OFAC can require a company to settle for whatever amount it deems fit. Here the settlement was for about 3% of the initial proposed penalty amount, but still relatively high given the number of substantive violations found.

2) "Unique mitigating factor"

501.601 of the provides as follows:

"Except as otherwise provided, every person engaging in any transaction subject to the provisions of this chapter shall keep a full and accurate...

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Civil Enforcement Information - DHL

TURBOFAC Commentary (854 words)