Enforcement Release - Alliance Steel, Inc.

Date issued: Apr. 19 2021

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

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.