The U.S. Treasury Department said Wednesday it has fined Network Hardware Resale LLC, a global telecommunications and networking equipment provider, nearly $65,000 for allegedly violating U.S. sanctions against Sudan and Iran between 2008 and 2011.
Treasury’s Office of Foreign Assets Control (OFAC) stated in a penalty notice that NHR exported 16 shipments of networking equipment and related accessories from the United States to Sudan, and two shipments destined for Iran.
The Santa Barbara, California-based company demonstrated “reckless disregard” for U.S. sanctions by failing to implement “even basic OFAC compliance measures” prior to discovering the alleged violations and disclosing them to the Treasury Department, OFAC said.
The apparent violations consisted of 18 transactions over the course of almost three years, OFAC said, showing “a pattern of conduct.”
Since NHR took prompt corrective action in response to the apparent violations, cooperated with OFAC during its investigation, and had no prior sanctions history, OFAC classified the case as “non-egregious.” The base penalty amount for the alleged violations is normally $143,906.
Julie DiMauro is the executive editor of FCPA Blog and can be reached here.