Last week, OFAC announced that it has reached a $871,837 settlement with MID-SHIP Group LLC (“MID-SHIP”). The Settlement Agreement notes that in 2011, MID-SHIP (a ship broker) processed transfers of funds related to payments for five apparent violations of the Weapons of Mass Destruction Proliferators Sanctions Regulations. OFAC Notice, Settlement Agreement and Enforcement Information. Per the settlement agreement, in 2011 MID-SHIP processed funds transfers totalling $472,861 relating to payments associated with blocked vessels identified on OFAC’s SDN list as being vessels owned or controlled by the Islamic Republic of Iran Shipping Lines (IRISL).
OFAC determined that MID-SHIP did not voluntarily self-disclose the apparent violations, and the apparent violations constitute an egregious case.
This is a summary. Click the links to get the full documents.