By: Danielle McClellan
Great Plains Stainless Co. (GPS) of Tulsa, Oklahoma has agreed to pay $214,000 to settle allegations that it violated the Office of Foreign Assets Controls (OFAC) regulations in 2009. GPS sold goods that its Chinese vendor shipped from Shanghai to GPS’s customer in Dubai via MN Sahand, a vessel that is considered blocked property (EO 13382). GPS also created new bogus trade documents, with references to the blocked vessel to be removed and then transferred these altered documents to its Dubai customer to facilitate the release of the goods that were held at the port in Dubai.
GPS did not voluntarily disclose these violations to OFAC, the maximum penalty could have been $500,000. The settlement amount is reflective of the following:
- GPS acted willfully since they altered the bill of lading
- They disregarded verbal and written guidance from OFAC stating that the company should consult with OFAC’s Licensing Division before engaging in the transaction
- GPS had submitted a license application to OFAC seeking authorization for this transaction and was denied but followed thru with the transaction
- They did not have a compliance program in place at the time of the alleged violations.
- The company has not received a penalty notice or Finding of Violation from OFAC in the past five years
- GPS had no reason to know that the blocked vessel was to be used for the shipment until the vessel’s sailing date
- They are a small company
- GPS took remedial measures to prevent future violations
Read the full document at: http://www.treasury.gov/resource-center/sanctions/CivPen/Documents/20150724_gps.pdf