Enforcement Release: Córdoba Music Group LLC

Date issued: Dec. 18 2024

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TURBOFAC Commentary (186 words)

Notes:

1) From a legal basis standpoint, this enforcement action is as straightforward as they come with respect to the exportation of goods to a third country with reason to know that they are destined for Iran (560.204), but not how OFAC only appears to count the actual exports as violations, rather than having “maintained a distribution agreement with a Dubai-based company for sales in the Middle East, including Iran” and having “entered into an informal arrangement [with an Iranian company] for it to distribute Córdoba products in Iran”. Compare Enforcement Release - NewTek, Inc. and Ubiquiti Networks. It is possible that the agreement-related “transactions” were outside the statute of limitations, and that’s why they weren’t cited as violations.

2) It is noteworthy that this is the lowest penalty assessed to an entity by OFAC since...