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ENFORCEMENT INFORMATION FOR MAY 2, 2019
MID-SHIP Group LLC Settles Potential Civil Liability for Apparent Violations of the Weapons of Mass Destruction Proliferators Sanctions Regulations: MID-SHIP Group LLC (“MID-SHIP”), headquartered in Port Washington, New York, has agreed to pay $871,837 to settle its potential civil liability for five apparent violations of the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544 (WMDPSR). Specifically, between on or about February 18, 2011 and on or about November 14, 2011, MID-SHIP processed five electronic funds transfers, totaling approximately $472,861, that pertained to payments associated with blocked vessels identified on OFAC’s List of Specially Designated Nationals and Blocked Persons (the “SDN List”).
OFAC determined that MID-SHIP did not voluntarily self-disclose the apparent violations to OFAC, and that the apparent violations constitute an egregious case. Both the statutory maximum and base civil monetary penalty amounts...
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1) Further factual information available at Settlement Agreement (OFAC) - MID-SHIP Group LLC (2019).
2) BASES FOR LIABILITY
a) OFAC says that:
between on or about February 18, 2011 and on or about November 14, 2011, Respondent appears to have violated § 544.201 of the WMDPSR when Respondent dealt in blocked property or interests in blocked property by processing five electronic funds transfers, totaling approximately $472,861, that pertained to payments associated with blocked vessels identified on OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDN List”).
There are several things notable about this. First there is a recognition that it was only the processing of the payments that was found to violate the law. It is consistent with OFAC's past practice to consider payments...