Enforcement Release: C.H. Robinson International Inc.

Date issued: Dec. 13 2024

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TURBOFAC Commentary (567 words)

Notes:

1) If C.H. Robinson International Inc. were a U.S. person, nothing about the legal basis for this enforcement action would be novel or notable. It is well established that U.S. persons cannot engage in dealings with Cuban- or Iranian-origin goods, ship goods to or from those countries, or ship goods to an Iranian airline. However, this case is, at least in part, based on violations of 560.215 where non-U.S. persons owned or controlled by a U.S. person were penalized for, among other things, having "acted in eight instances as a customs broker for the importation into Australia of Iranian-origin goods from Germany, Spain, Singapore, and Iran valued at $148,196." This, according to OFAC, is a violation of 31 C.F.R. § 560.215 because the transactions are "trade-related transactions involving Iranian-origin goods that would have been prohibited by § 560.206 if engaged in by a U.S....