OFAC Settlements: When Good Intentions Aren’t Enough
27 Feb 2019

On February 7th, Kollmorgen Corporation (“Kollmorgen”) of Radford, Virginia, agreed to a settlement with the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) for six apparent Iran sanctions regulations violations by its Turkish affiliate Elsim Elektroteknik Sistemler Sanayi ve Ticaret Anonim Sirketi (“Elsim”). Despite significant preventative, investigatory, and remedial efforts by Kollmorgen, the $13,381 settlement was almost double the $7,434 base penalty.

Why? Good question. Let’s examine the facts and timeline first.

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