Calif. Firm to Pay $404,100 on Charges of Illegal Exports to Iran
American Optisurgical, Inc., of Lake Forest, Calif., agreed to pay $404,100 to settle potential civil liability for alleged violations of the Iranian Transactions and Sanctions Regulations from 2005 to 2010, said the Treasury Department's Office of Foreign Assets Control. It…
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said AOI violated the ITSR on 36 occasions when it exported, or attempted to export, unlicensed medical goods and services to Iran, or to a person in a third country who knew or should have known that the medical goods and services were intended for Iran. OFAC also alleged that AOI violated the RPPR when it failed to fully respond to two Administrative Subpoenas issued to AOI by OFAC. The alleged violations involved transactions valued at $202,765, OFAC said. It said AOI didn't voluntarily self-disclose the matter to OFAC, but the alleged violations constituted a non-egregious case. It said AOI's alleged violations resulted from willful or reckless conduct; AOI's senior management was directly involved in the willful or reckless conduct; AOI actively participated in concealing the ultimate destination of its exports to Iran; AOI continued to export unlicensed medical goods to Iran even after having received two Administrative Subpoenas from OFAC regarding its conduct; AOI is a commercially sophisticated entity; AOI has not been the subject of prior OFAC enforcement action; the exports at issue likely would have been licensed by OFAC under existing licensing policy; and, AOI agreed to toll the statute of limitations.