Articles Tagged with #Sanctionsviolations

Resit Tavan, a Turkish Businessman and owner of the Istanbul-based Turkish business Ramor Dis Ticaret Ltd. (also known as the “Ramor Group”) was sentenced on Thursday, Aug. 29, 2019, in Federal District Court in Milwaukee, Wisconsin, to 27 months imprisonment in connection with his conviction for conspiracy to violate U.S. sanctions by exporting specialized marine equipment from the United States to Iran between 2013 to 2015. Tavan, a Turkish citizen, had pleaded guilty to a conspiracy to violate U.S. sanctions on Iran under the International Emergency Economic Powers Act by using his Turkish based company, the Ramor Group, to acquire a range of marine related equipment that had been manufactured in Wisconsin by U.S. companies, including high powered outboard engines, marine power generators and power boat propulsion equipment known as surface drives, on behalf of the Iran-based Qeshm Madkandalou Shipbuilding Cooperative (Madkanadalou).  Evidence introduced in Court showed that Tavan had worked in cooperation with Iranian officers associated with Madkandalou to use some of this U.S. origin marine equipment to support the construction and development of a prototype high-speed missile attack boat for the Iranian military or naval forces.  From early 2013 through 2015, Tavan and the Ramor Group had worked in concert with Iranian officials to procure U.S. origin marine equipment and illegally export it to Iran by using the Ramor Group in Turkey to receive the goods and thereafter re-export it to Madkandalou in Iran, in violation of U.S. sanctions.

At the sentencing hearing, the District Court Judge indicated that this conspiracy to violate U.S. sanctions by procuring marine equipment for military purposes represented a serious threat to U.S. national security.  The Judge also found that Tavan’s role in the offense should be considered in connection with the overall direction and control of the project by higher ranking Iranian officials.

At no time did anyone involved in these transactions obtain permission from the U.S. Department of Treasury, Office of Foreign Assets Control or the U.S. Department of Commerce to export any U.S.-origin marine equipment from the United States to Iran.

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC)has fined a U.S. truck maker PACCAR $1.7 million for 63 alleged violations of the Iranian Transactions and Sanctions Regulations. The settlement resolves potential civil liability for actions taken by a wholly-owned subsidiary of the company that allegedly sold or supplied trucks with a total transactional value of over $5.4 million to European customers, but knew or had reason to know the trucks were ultimately intended for buyers in Iran.

In arriving at the settlement amount, various mitigating factors were considered, including that (i) neither the company nor the subsidiary have received a penalty or finding of a violation in the five years prior to the transactions at issue; (ii) the subsidiary had in place at the time of the alleged violations a trade sanctions compliance program with contractual prohibitions on dealers and service partners that were re-selling products in violation of U.S. trade sanctions; and (iii) the company and subsidiary voluntarily self-disclosed the issue to OFAC, cooperated with OFAC during the investigation, and undertook remedial efforts to minimize the risk of similar violations from occurring in the future.

The Treasury also considered various aggravating factors, including that the subsidiary failed to exercise caution when alerted to warning signs regarding the potential sales, and that in each instance, a subsidiary employee was aware of the conduct leading to the alleged violations.