On 6 May 2014, OFAC announced that an individual from Washington state paid $29,340 to settle alleged violations of the Iranian Transactions and Sanctions Regulations. OFAC did not identify the individual by name. According to OFAC, between May 2007 and November 2009, the individual, acting as a third-party recipient, sold, exported and supplied unlicensed medical goods and related financial services to Iran. The alleged violations comprised 19 separate transactions with a total value of $49,341.
OFAC determined that the individual did not voluntarily disclose the matter and the alleged violations constituted a non-egregious case. OFAC considered as an aggravating factor that the individual demonstrated reckless conduct by persisting in the conduct after OFAC issued a warning letter for similar past activities. In mitigation, OFAC considered that the individual had not previously received a penalty notice, that the medical goods were potentially licensable under existing OFAC policy and that the individual cooperated with OFAC’s investigation and agreed to toll the statute of limitations.