DIFFERENT ANGLE by Kenneth Rijock
Treasury has announced that the latest three Civil Penalty and Enforcement Information press releases, for February and March 2010, have been published* to the OFAC website. The magnitude of the civil fines, some of which have been accompanied by criminal penalties,** should indicate to you the zero tolerance approach that US law enforcement takes with violators of the existing sanctions against Iran. if you have any bank clients who, directly or indirectly, may be dealing with Iran, whether through Dubai or otherwise, you need to look at this.
- An aviation services company was fined $ 750,000 for the unlicensed export of aircraft parts to Iran.
- A maritime firm paid $72,000 for transporting equipment to Sudan.
- An aviation firm that sold airliners to Iran paid a $15m civil penalty.
- Insist on a notarised certificate from the client, attesting to the identity of the end user. Make an unannounced visit to the client's office and request to see the files. if they decline, terminate the client.
- Require the bank that will be sending you final payment for those goods to list all their correspondent banks. If there are any Iranian banks on that list, terminate the transaction, and consider terminating your relationship with the client. Turn the matter over to your outside counsel, who can then determine whether you need to report the transaction.
The facts and opinions stated in this article are those of the author and not those of World-Check. World-Check does not warrant the accuracy of any facts and opinions stated in this article, does not endorse them, and accepts no responsibility for them.
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