OFAC Enforcement Update

The Treasury Department's Office of Foreign Assets Control (OFAC) implements and enforces US economic sanctions.  These sanctions proscribe certain transactions with various governments, businesses, groups, and individuals.  OFAC issued its latest enforcement update on November 8, 2011; the two civil penalties identified in the update are quite modest, but the circumstances described underscore noteworthy trends in published OFAC enforcement cases.

In the first case, Wilson Tool International agreed to pay $15,000 to settle an alleged violation of the Iranian Transactions Regulations.  Without a license, Wilson allegedly sold approximately $10,304 worth of tooling equipment to an entity in Iran in 2005.  In the second case ASF, Inc. agreed to pay $5,400 to settle an alleged violation of the Iranian Transactions Regulations.  Without a license, ASF allegedly facilitated the exportation of goods from a third country to Iran in 2006 (OFAC did not disclose the type or