PanAmerican Seed pays $4.3 million settlement for trade with Iran
OFAC determined that PanAm Seed did not voluntarily self-disclose the Alleged Violations to OFAC, and that the Alleged Violations constitute an egregious case. Both the statutory maximum and base penalty civil monetary penalty amounts for the Alleged Violations were $12,000,000.
For a number of years, up to and including 2012, PanAm Seed made 48 indirect sales of seeds to two Iranian distributors. PanAm Seed shipped the seeds to consignees based in two third-countries located in Europe or the Middle East, and PanAm Seed’s customers arranged for the re-exportation of the seeds to Iran. Personnel (including several mid-level managers) from various business units within PanAm Seed and/or Ball Horticultural were aware of U.S. economic sanctions programs involving Iran and the need to apply for and obtain a specific license from OFAC in order to export the seeds in question. Despite this knowledge, PanAm Seed engaged in a pattern or practice designed to conceal the involvement of Iran and/or obfuscated the fact that the seeds were ultimately destined for distributors located in Iran.
Click here to see the full details of the settlement between OFAC and PanAm Seed.
The Export Law Blog has posted some comments on the settlement ruling.