An Iranian businessman was sentenced to 46 months in prison for illegally exporting carbon fiber from the U.S. to Iran, the Justice Department said Nov. 14. Behzad Pourghannad worked with two others between 2008 and 2013 to export the carbon fiber to Iran from third countries using falsified documents and front companies, the agency said.
OFAC Sanctions Activity
OFAC administers multiple sanctions programs, including country-specific programs or restrictions against human rights violators, weapons proliferators, narcotics traffickers and more. The agency can impose penalties on people and entities that violate those programs. Here are recent stories about OFAC sanctions activity:
Apple was fined about $465,000 for violations of the Foreign Narcotics Kingpin Sanctions Regulations after it hosted, sold and “facilitated the transfer” of software applications and content belonging to a sanctioned company, the Treasury’s Office of Foreign Assets Control said in a Nov. 25 notice. Apple allegedly dealt in “the property and interests” of SIS d.o.o., a Slovenian software company added to OFAC’s Specially Designated Nationals List in 2015.
Export Compliance Daily is providing this recap of sanctions and export controls enforcement over the past year. Intended to assist export compliance professionals, lawyers and others in the export world stay up to date with current enforcement trends, this guide includes summaries of prominent enforcement actions by the Treasury's Office of Foreign Assets Controls, the Commerce Department's Bureau of Industry and Security, and the Justice Department since Export Compliance Daily began publishing in March 2019.
A Florida-based aviation investment management company was fined about $210,000 after it committed 12 violations of U.S. sanctions against Sudan, Treasury’s Office of Foreign Assets Control said in a Nov. 7 notice. The company, Apollo Aviation Group, which has since been bought by The Carlyle Group and is now Carlyle Aviation Partners, committed the violations in transactions involving the lease of three aircraft engines, the notice said. Apollo allegedly leased the engines to a United Arab Emirates company, which subleased the engines to a Ukrainian airline, which installed the engines on an aircraft wet leased to Sudan Airways.
A recent fine on a U.S. company while simultaneously penalizing the manager of the company's foreign subsidiary after both violated sanctions on Iran seems reflective of the increasingly aggressive nature and number of U.S. enforcement actions taken on sanctions violations during the last few months, according to several Washington trade lawyers. The fine was called “unprecedented” in early February by the Department of the Treasury. After distributing just one penalty through the first eight months of 2018, the Office of Foreign Assets Control doled out six penalties during the last four months of 2018, according to the office's records. And two months through 2019, OFAC already has administered four penalties worth more than $7 million, according to the agency, including a $5.5 million penalty against the German subsidiary of an Illinois-based company on Feb. 14.