OFAC Enforcement Action: Another Grand Slam Penalty

Today OFAC released an enforcement action against Alma Investment LLC, a quasi-investment and trading company in the UAE that decided it wanted to violate the ITSR. This case and the penalties seem very similar to another grand slam almost exactly a month ago. While N=2 does not make a pattern, this is the second time OFAC has leveled the full amount of the base penalty under IEEPA against a trading company facilitating transactions with Iran in less than a 30 day period. Both cases were most likely concluded 30 days after the PPN was issued.

If OFAC is getting tough against these trading companies, I would suspect that we will start to see an uptick on these enforcement actions. Likewise, OFAC not so subtly couched their rationale for this focus as that “assessing a civil monetary penalty against Alma will have a compliance/deterrence effect by encouraging greater due diligence by foreign financial institutions that maintain accounts for third-country trading companies and/or money transmitters.” Enough said.