On 25 June, OFAC announced that Network Hardware Resale LLC (“NHR”), a California-based reseller of used computer networking equipment, agreed to pay $64,758 to settle potential civil liability for 16 shipments of networking equipment and related accessories to Sudan and two similar shipments to Iran.  OFAC determined that NHR voluntarily disclosed the matter and that it constitutes a non-egregious case.

According to OFAC’s announcement, the settlement amount reflects that NHR is a sophisticated company with worldwide operations; that NHR demonstrated reckless disregard by engaging in worldwide commerce without a sanctions compliance programme; that the potential violations  reflect a pattern of conduct that took place over three years; that NHR took prompt corrective  action and cooperated with OFAC in the investigation, including tolling the statute of limitations; and that NHR has no prior sanctions violations in the five years preceding the earliest apparent violation.

OFAC Enforcement Announcement