Civil Enforcement Information - Alliance Steel, Inc.

Date issued: Apr. 19 2021

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TURBOFAC Commentary (112 words)

Notes:

1) From a legal basis standpoint, the Alliance Steel, Inc. enforcement action is extremely straightforward. The use of an Iranian professional service provider is an “importation” of services from Iran (560.201) and a trade-related transaction involving Iranian origin services (560.206).

What is notable about the enforcement action is the fact that the entity penalized is a U.S-based manufacturer that does not actually export (i.e., the entity would ordinarily be considered to have a low sanctions risk profile). OFAC noted this in the enforcement release, evidently to flag its enforcement intentions vis-à-vis entities that would generally not be expected to have sophisticated OFAC compliance programs.