OFAC, Alcon Reach Settlement on Alleged Iran, Sudan Sanctions Violations
The Office of Foreign Assets Control and Alcon Laboratories have reached a $7.6 million settlement agreement to settle potential civil liability stemming from 452 alleged violations of Iran sanctions regulations and 61 violations of Sudan sanctions regulations, after Alcon sold…
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and exported medical end-use surgical and pharmaceutical products to the countries without OFAC authorization, the agency said (here). OFAC found that Alcon didn’t make a voluntary self-disclosure, and showed “reckless disregard” for sanctions requirements by not maintaining a compliance program, but said that Alcon’s alleged violations were not egregious. Mitigating factors that OFAC determined include Alcon’s blank sanctions violation history, the company’s cooperation with OFAC, and the apparent actions’ minimal harm to U.S. sanctions objectives, because the exports involved licensable medical end-use products, OFAC said.