On 31 October 2014, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that Indam International, Inc., a Texas-based oil services provider that specialises in providing
for on/offshore drilling, well servicing and production equipment to the oil industry worldwide, agreed to pay $44,850 to settle potential civil liability for nine shipments of goods from the United States to the United Arab Emirates with reason to know that the shipments were intended specifically for supply to two oil drilling rigs destined for or located in Iranian waters.
OFAC determined that Indam did not voluntarily self-disclose the apparent violations and that they constitute a non-egregious case. However, OFAC determined that Indam demonstrated reckless disregard for US sanctions requirements by failing to conduct due diligence on the end users of its products; Indam was aware that exporting goods for use on Iranian oil rigs is a violation of the Iranian sanctions; Indam’s management had reason to know of the apparent violations; and Indam did not implement appropriate policies and procedures to ensure compliance with US sanctions laws. Mitigating these considerations, OFAC noted that Indam did not have actual knowledge that the goods were to be used on Iranian oil rigs (but had reason to know because the facts were publically available at the time of the apparent violations), the harm was mitigated because five of the nine shipments were detained by US Customs and Border Protection, Indam is a small business, Indam had not received a penalty notice or Finding of Violation in the five years preceding the earliest apparent violation, Indam has taken remedial measures, Indam cooperated with OFAC (including by agreeing to toll the statute of limitations), and Indam forfeited the goods involved in at least four of the apparent violations.