Two recent OFAC Civil Penalties notices demonstrate that zero-tolerance continues to be the order of the day for companies that do not follow the precise letter of the law on Iran sanctions.
(1) Deutsche Bank Trust Company Americas was fined $18,900 for rejecting, rather than blocking, a funds transfer involving Bank Melli. The lesson of the penalty: banks must have the SWIFT/BIC codes for blocked financial institutions in their interdiction software. It also did not help that several compliance officers, including a supervisor for OFAC matters, did not block the transaction.
(2) Communications and Power Industries LLC drew a civil penalty of $346,530 for selling medical equipment to an Iranian purchaser. The covert way that the transaction was conducted is noteworthy; the company's Swiss subsidiary directed its Canadian affiliate to ship the equipment to Turkey. OFAC stated that, had an application for a license been submitted, it probably would have been granted.