Below, we describe OFAC’s action in more detail and provide recommendations for ensuring compliance.Īccording to the settlement agreement, between August 2010 and November 2011, TransTel entered into contracts with multiple Iranian companies to deliver and install telecommunications equipment for a number of energy projects in Iran and/or Iranian territorial waters. companies that do business with OFAC-sanctioned jurisdictions or persons should be aware of the significant risks of using U.S. While this particular case involves Iran sanctions-and could reflect the Trump Administration’s policy of more aggressively confronting Iran -it likely signals a broader enforcement trend that applies across the range of U.S. dollar transactions involving sanctioned countries, especially where the banks were alleged to have knowingly removed (or helped their customers to remove) information indicating a link to the sanctioned country OFAC has chosen not to pursue the banks’ customers that initiated these transactions. Historically, OFAC has focused its enforcement resources on penalizing non-U.S. dollar payments involving a sanctioned country. This action is significant because it appears to be the first time OFAC has penalized a non-U.S., non-financial company for “causing” sanctions violations by initiating U.S. dollar payments) from the United States to Iran or for the benefit of Iran. sanctions by engaging in the prohibited exportation of financial services ( i.e., processing U.S.
financial system and caused multiple financial institutions to violate U.S. These payments (which did not indicate their relation to Iran) were processed through the U.S. dollar account at a Singapore-based bank to make over $11 million in payments to various third-party vendors-including several Iranian companies-that were providing goods and services in connection with the Iranian contracts. According to the settlement, TransTel apparently violated U.S. TransTel entered into contracts to install telecommunications equipment for several Iranian energy projects. (“TransTel”), which are both based in Singapore. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced a $12 million settlement with CSE Global Limited (“CSE Global”) and its subsidiary, CSE TransTel Pte. Having Historically Targeted Banks, OFAC Signals Interest in Penalizing Banks’ Customers That Send Illegal Payments through the U.S.
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