Colorado Medical Equipment Firm to Pay $126,000 to Settle OFAC Allegations
Sandhill Scientific, Inc. of Highlands Ranch, CO, which makes medical equipment, agreed to remit $126,000 to settle allegations that it violated the Iranian Transactions Regulations, 31 CFR part 560 (the "ITR") in May 2007, and OFAC's Reporting, Procedures and Penalties Regulations, 31 CFR part 501 (the "RPPR"), on separate occasions in May and July 2008, Treasury's Office of Foreign Assets Control said April 25.
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OFAC had alleged that Sandhill exported medical equipment in 2007 valued at approximately $6,700 to Dubai, United Arab Emirates, with reason to know the goods were intended for transshipment to a company in Iran with which Sandhill had an exclusive distributor agreement. OFAC also alleged that Sandhill failed to provide documents responsive to two administrative subpoenas issued by OFAC during its investigation.
OFAC decided the alleged ITR violation constituted an egregious case because Sandhill's unlicensed export appears to have resulted from willful and reckless conduct in which the company's management was directly involved. It also said Sandhill appeared to have deliberately concealed that the goods were destined for Iran, and did not fully cooperate with the investigation. These determinations resulted in a base penalty amount of $250,000 for the alleged ITR violation.
OFAC also said Sandhill does not appear to have had any compliance program in place at the time of the alleged violations, and does not appear to have taken any remedial action after the alleged violations came to its attention. But it noted that OFAC has no record of any prior sanctions enforcement actions involving Sandhill.