Enforcement Information for February 7, 2019

February 7, 2019

Information concerning the civil penalties process can be found in the Office of Foreign Assets Control (OFAC) regulations governing each sanctions program; the Reporting, Procedures, and Penalties Regulations, 31 C.F.R. part 501; and the Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A. These references, as well as recent final civil penalties and enforcement information, can be found on OFAC’s Web site at www.treasury.gov/ofac/enforcement.

ENTITIES – 31 CFR 501.805(d)(1)(i)

Kollmorgen Corporation Settles Potential Civil Liability for Apparent Violations of the Iranian Transactions and Sanctions Regulations: Kollmorgen Corporation (“Kollmorgen”), a company based in Radford, Virginia, on behalf of its Turkish affiliate, Elsim Elektroteknik Sistemler Sanayi ve Ticaret Anonim Sirketi (“Elsim”), has paid $13,381 to settle potential civil liability for six apparent violations of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR). Specifically, between July 2013 and July 2015, Elsim  appears to have violated § 560.215 of the ITSR when, on six occasions, Elsim serviced machines containing Elsim products located in Iran and provided products, parts, or services valued at $14,867 with knowledge they were destined for Iranian end-users (collectively referred to hereafter as the “Apparent Violations”).

Kollmorgen acquired control of Elsim in early 2013, thereby making Elsim subject to the ITSR’s prohibitions for any activity or conduct engaged in by Elsim, including conduct or activity occurring outside of the United States. Prior to the acquisition, Kollmorgen hired an external law firm and an external auditing and consulting company to perform sanctions due diligence on Elsim. The due diligence results demonstrated that Elsim made sales to, and had customers in, Iran prior to its acquisition by Kollmorgen. Based on these results,  Kollmorgen determined it would need to take steps to prevent such sales from occurring in the future and educate Elsim on the applicability of U.S. sanctions.