Enforcement Release: Harman International Industries, Inc

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 (512 words)

Notes:

1) Except as described below, this is a fairly standard set of 560.204 violations based on the exportation of goods from the U.S. to a third country distribution (the UAE being a common one) with knowledge or reason to know that the goods are destined for Iran. Compare e.g. Epsilon Electronics Inc. (2 of 2 - 2018). Similar to the Epsilon case, the facts as described by OFAC raise interesting questions about the degree of evidence OFAC had that each of the 12 shipments at issue did, in fact, reach Iran. OFAC acknowledges that “Harman Pro had no direct visibility into the disposition of the goods once the Distributor obtained them from the Danish warehouse, members of Harman Pro’s British Sales Team understood the Distributor’s practice of channeling Harman goods it received in Denmark to Iran”. Did OFAC assume (or “determine” based...

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Enforcement Release: Harman International Industries, Inc

TURBOFAC Commentary (512 words)