OFAC and BIS have entered a joint settlement agreement with DPWN Holdings (USA), Inc. and DHL Express (USA), Inc. regarding allegations that the carrier aided and abetted unlawful exports to embargoed countries Syria, Iran and Sudan and failed to comply with record-keeping obligations related to such exports. BIS alleged eight occurrences of aiding and abetting unlawful exports to Syria in 2004 and 90 instances of failing to retain air waybills and other export control documents, as required under the EAR. OFAC likewise identified record-keeping violations, and other violations of OFAC regulations in connection with thousands of shipments to Iran and Sudan between 2002 and 2006. Under the joint settlement agreement, DHL will pay a US$9.4 million civil penalty and engage an expert in export control laws and sanctions programs to conduct a comprehensive audit of transactions involving Iran, Sudan and Syria occurring between March 2007 and December 2009. In addition, the company will commission full-year 2010 and 2011 audits.