Minnesota Company Fined US$257,690.00 By OFAC For Unauthorized Cuba/Iran Transactions. Fine Could Have Been US$28.6 Million. Fine Is .9% Of Potential Liability.
/Enforcement Release: December 13, 2024
C.H. Robinson International Inc. Settles with OFAC for $257,690 Related to Apparent Violations of the Iranian Transactions and Sanctions Regulations and the Cuban Assets Control Regulations
C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle potential civil liability relating to 82 apparent violations of sanctions against Iran and Cuba conducted by five of its non-U.S. subsidiaries. Over a period of more than three years, these subsidiaries provided freight brokerage or transportation services for 82 shipments, to or from Iran, of Iranian- or Cuban-origin goods, or by dealing with an Iranian airline. The settlement amount reflects the Office of Foreign Assets Control’s (OFAC) determination that the apparent violations were non-egregious and voluntarily self-disclosed, as well as the remedial measures implemented by CHR upon discovery of the apparent violations.
Penalty Calculations and General Factors Analysis
The statutory maximum civil monetary penalty applicable in this matter is $28,629,270. OFAC determined that CHR voluntarily self-disclosed the Apparent Violations and that the Apparent Violations constitute a non-egregious case. Accordingly, under OFAC’s Economic Sanctions Enforcement Guidelines (“Enforcement Guidelines”), 31 C.F.R. Part 501, app. A, the base civil monetary penalty applicable in this matter equals the sum of one-half of the transaction value for each apparent violation, which is $322,112. The settlement amount of $257,690 reflects OFAC’s consideration of the General Factors under the Enforcement Guidelines.
