Washington Man Sentenced in Conspiracy to Export Sophisticated Computer Equipment to Iran

A Florida judge sentenced John Alexander Talley of Seattle, Washington, to 30 months in prison in late April 2014, in part, for conspiracy to violate the Iranian Transaction Regulations (now known ITSR). The judge also sentenced Talley’s company, Tallyho Peripherals, Inc. (“Tallyho”), to one-year probation on the same grounds. Court documents indicate that Talley and Tallyho took part in a conspiracy to export sophisticated computer equipment from the United States to Iran and to provide related IT support services. Conspirators transshipped the computer equipment through the United Arab Emirates (UAE), and payments to Talley for providing IT training and support similarly passed through the UAE. Read the BIS press release and coverage from the Tampa Bay Business Journal.

Decolar.com, Inc. Settles Potential Civil Liability for Apparent Violations of the Cuban Assets Controls Regulations

Decolar.com, Inc., a U.S. company with headquarters in Buenos Aires, Argentina, along with its subsidiaries and affiliates (collectively, “Decolar”), agreed to a settlement of USD $2.8 million with OFAC in early May 2014 regarding allegations that it violated the CACR by providing travel-related services involving Cuba. OFAC alleged that Decolar’s foreign subsidiaries assisted over 17,800 individuals with Cuba-related flight and hotel reservations over a span of three years. The large settlement amount apparently reflects OFAC’s consideration of the following factors: the company’s senior managers appeared to have known of the Cuba-related services; the alleged violations, representing a large volume of transactions over an extended period of time, appeared to have resulted from a pattern or practice of conduct; and, despite Decolar’s sophistication as a travel services provider, it did not have an OFAC risk-based compliance program in place during the period of the alleged violations. With a base penalty amount of USD $4,460,000, however, the settlement amount also reflects OFAC’s assessment that the apparent violations represented only a small portion of Decolar’s business and recognition of Decolar’s subsequent adoption of OFAC compliance policies and procedures. Read the OFAC enforcement action and Havana Times coverage.