A satellite telecommunications company settled its potential civil liability with OFAC for apparent violations of the Sudanese Sanctions Regulations ("SSR").
According to OFAC, the company's wholly-owned subsidiary indirectly exported communications equipment, and facilitated services and training, for a Sudanese government-owned entity, despite prohibitions against such transactions under the SSR. OFAC alleges that, despite numerous red flags presented to the subsidiary and its former Director of Logistics and Export Compliance Official, the shipment of equipment was allowed to proceed. Further, OFAC alleged that the former Director of Logistics and Export Compliance official approved subsequent warranty work on the equipment, even though a pending OFAC license application had not been approved.
In connection with the settlement, OFAC stated that the company had committed to making several personnel hires to improve its sanctions compliance program. OFAC determined that the company voluntarily self-disclosed the apparent violations, but that the conduct constituted an egregious case due, in part, to apparent efforts by the former Director of Logistics and Export Compliance to manipulate documents provided to OFAC during its investigation.
To settle the charges, the company agreed to pay $894,111.
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