OFAC Settles with Genesis Asset Over Alleged Violations of ITR
Genesis Asset Managers agreed to pay $112,500 to settle potential civil liability for an apparent violation of the Iranian Transactions Regulations, 31 C.F.R. part 560, about August 1, 2007, said the Treasury Department Office of Foreign Assets Control.
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GAM affiliate GIM UK bought about $3 million of stock in the First Persian Equity Fund ("FPEF"), a Cayman Islands company that invests exclusively in Iranian securities, in violation of the rules, OFAC said. It said GAM US failed to exercise a minimal degree of caution or care in the conduct that led to the apparent violation of the ITR; officers of GAM US were aware of the conduct giving rise to the apparent violation; substantial economic benefit was conferred to Iran, thereby undermining the objectives of the ITR; and GAM US did not have an OFAC compliance program in place at the time of the apparent violation.
But OFAC said mitigating factors included that GAM US has not previously been accused of similar violations; it cooperated with OFAC's investigation, including voluntarily self-disclosing the apparent violation, and by agreeing to settle this matter without additional proceedings; it took appropriate remedial action; and GAM US may not have fully understood its OFAC obligations under U.S. law.