Maersk Line, Limited and its wholly owned subsidiaries, Farrell Lines Incorporated and E-Ships, Inc. (collectively, Maersk) settled allegations of violations of the Iranian Transactions Regulations and Sudanese Sanctions Regulations with OFAC for US$3.1 million. Between January 2003 and October 2007, Maersk provided services for 4,714 unlicensed shipments of cargo originating in or destined to Iran or Sudan. Although Maersk did not voluntary disclose its conduct, OFAC significantly mitigated the penalty – from a base penalty of US$61.8 million – for the following reasons: (i) Maersk had no other OFAC violations in the past five years; (ii) Maersk and its parent engaged in remediation measures throughout the entire corporate group to ensure future compliance with US sanctions; and (iii) Maersk cooperated fully with OFAC’s investigation by providing large amounts of well-organized data regarding its shipments involving Iran and Sudan as well as detailed information not specifically requested by OFAC.