The Office of Foreign Assets Control (OFAC) is tasked with ensuring that the country’s national security goals are upheld by minimizing financial transactions that pose threats to the nation. To effectively reach their goals, the OFAC has the power and authority to financially penalize, sanction, and even levy criminal charges against individuals, entities, and governments who don’t adhere to their regulations.

In a recent move, the agency levied 82 sanctions violations charges against C.H. Robinson International Inc. (CHR), which is a Minnesota-based company that specializes in global transportation and logistics. According to OFAC reports, the company has five non-U.S. subsidiaries who were providing transportation services and freight brokerage to or from Iran or with Iranian and Cuban goods. These shipment services were provided illegally at least 82 times over a period of three years.

Reports suggest the incidents happened between November of 2018 and February of 2022. In at least 73 instances, shipments were made of Iranian-origin goods, and in six instances, shipments were made of Cuban-origin goods

These actions directly violate Iranian Transactions and Sanctions Regulations 31 C.F.R. part 560 and 31 C.F.R. part 515. Another subsidiary based in Guangzhou is accused of providing transportation services for a shipment from China to Turkey. CHR Spain sent textile machinery from Spain to Iran. CHR Canada, CHR Australia, and CHR Peru were also implicated in shipping to Iran or from Iran.

One thing that worked in the company’s favor in this case is that CHR self-disclosed the violations as soon as they reasonably became aware of what was happening. What’s more, the company took self-corrective remedial measures as soon as they discovered the violations.

The OFAC also determined that the violations were non-egregious. Based on all those factors, the agency agreed to a settlement with the company. C.H. Robinson International Inc. will pay $257,690 to resolve the situation.

Are You Keeping Up With All Your Foreign Transactions?

Even though C.H. Robinson International willfully disclosed the violations to the OFAC, they were still subject to a $257,690 fine. That said, it could’ve been much, much worse.

An OFAC sanctions violation is punishable with criminal charges that could result in imprisonment for up to 30 years. Monetary fines can also range from several thousand dollars to several million dollars.

It’s a business’s responsibility to ensure that every transaction they’re conducting is with an individual or entity that isn’t sanctioned. Not knowing about the sanctions or not knowing that the entity or person was sanctioned isn’t a reasonable enough defense for you to avoid consequences, as is apparent in the case of C.H. Robinson International.

The best way to avoid facing criminal or monetary consequences as a result of violating OFAC sanctions is to hire a solid international lawyer who can help you ensure your business remains compliant with every foreign transaction. A quality lawyer will remain up to date with the latest changes to OFAC sanctions, and they’ll also be prepared to help you with any other legal obstacles you face.

Contact our team here at Bukh Global now to learn more about how we can help you and your business in the upcoming year.