OFAC Settles Allegation of Sudanese Sanctions Violation for $14K
The Office of Foreign Assets Controls has posted enforcement information for December 20, 2011 concerning a civil penalty of $13,500 assessed against Lanier Marine Liquidators of Dawsonville, Georgia, to settle allegations of violations of the Sudanese Sanctions Regulations (31 CFR Part 538) occurring between March 2005 and March 2006. OFAC alleged that LML entered into contracts to sell boats and boat parts to an individual in Sudan, and attempted to export a boat and boat parts to Sudan valued at $30,460.
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Penalty Was Reduced from $50K as Non-Egregious Case
The base penalty amount for the alleged violations was $50,000. OFAC determined that LML did not voluntarily disclose this matter to OFAC, however the alleged violations constitute a non-egregious case. The settlement amount reflects OFAC’s consideration of the following General Factors under OFAC’s Economic Sanctions Enforcement Guidelines: (1) LML has no history of prior OFAC violations; (2) LML substantially cooperated with OFAC’s investigation of the alleged violations and entered into tolling agreements with OFAC; and (3) LML took appropriate remedial action upon learning of the potential OFAC violations.