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September 12, 08

NEWS / ENFORCEMENT INFORMATION FOR August 1, 2008


ENFORCEMENT INFORMATION FOR August 1, 2008
Information concerning the civil penalty process is discussed in OFAC regulations
governing the various sanctions programs or, in the case of sanctions regulations
issued pursuant to the Trading with the Enemy Act, in 31 CFR part 501. Civil
penalty procedures are also discussed in OFAC’s proposed Enforcement Guidelines,
68 FR 4422 – 4429 (January 29, 2003). However, please note that, for banking
institutions regulated by one of the agencies belonging to the Federal Financial
Institutions Examination Council, the proposed enforcement guidelines have been
withdrawn and replaced by an interim final rule (“Economic Sanctions Procedures
for Banking Institutions”), 71 FR 1971 – 1976 (January 12, 2006), which has an
effective date of February 13, 2006. Both the proposed Enforcement Guidelines and
the interim final rule are available on OFAC’s website, available at
http://www.treas.gov/offices/enforcement/ofac/civpen/enfguide.pdf.
OFAC is now posting on this website copies of its final agency Penalty Notices with
the relevant case reports to the extent permitted under applicable law.
ENTITIES – 31 CFR 501.805(d)(1)(i)
Environmental Systems Research Institute, Inc. Settles Allegations of Violations of
the Iranian Transactions Regulations: Environmental Systems Research Institute, Inc.
(“ESRI”), of Redlands, CA has remitted $4,120.29 to settle allegations of violations of
the Iranian Transactions Regulations. The alleged violations occurred on or about
December 1, 2005 and March 1, 2007. OFAC alleged that ESRI attempted to send a
funds transfer to a company in the United Arab Emirates through the company’s Bank
Saderat account. ESRI did not voluntarily disclose this matter to OFAC but it has
instituted a comprehensive U.S. sanctions compliance program.
8e6 Technologies Settles Iranian Transactions Regulations Allegations: 8e6
Technologies, Orange, CA (“8e6”), has remitted $3,300 to settle allegations of violations
of the Iranian Transactions Regulations occurring between April 2000 and October 2003.
OFAC alleged that 8e6 acted without an OFAC license or outside the scope of its license
by exporting its internet services to Iran. 8e6 did not voluntarily disclose this matter to
OFAC.
Wire Pro Incorporated Settles Allegations of Violations of the Iranian Transactions
Regulations: Wire Pro Incorporated (“WPI”), of Salem, NJ, has remitted $2,932.50 to
settle allegations of violations of the Iranian Transactions Regulations. The alleged
violations occurred in September, 2003. OFAC alleged that WPI allegedly attempted to
use the services of Bank Saderat, an entity owned and controlled by the government of
Iran, to send a refund to a company in the United Arab Emirates without an OFAC
license. WPI did not voluntarily disclose this matter to OFAC.
HM Digital, Inc. Assessed a Penalty for Violating the Iranian Transactions
Regulations: HM Digital, Inc. (“HM”), Culver City, CA, has been assessed a $2,662.00
civil monetary penalty for its violation of the Iranian Transactions Regulations. On
February 2, 2006, HM attempted to export water testing equipment to an entity located in
Iran. HM did not voluntarily disclose this matter to OFAC. For a copy of OFAC’s
Penalty Notice issued to HM, please visit the following url:
http://www.treas.gov/offices/enforcement/ofac/civpen/penalties/hm_digital.pdf
Aerovacations, Inc. Assessed a Penalty for Violating the Cuban Assets Control
Regulations: Aerovacations, Inc. (“Aerovacations”), Los Angeles, CA, has been
assessed a $1,761.00 civil monetary penalty for its violation of the Cuban Assets Control
Regulations occurring on or about August 10, 2007. Aerovacations attempted to transfer
USD 2,709.54 to book a trip to Argentina for a Specially Designated National of Cuba.
Aerovacations did not voluntarily disclose this matter to OFAC. For a copy of OFAC’s
Penalty Notice issued to Aerovacations, please visit the following url:
http://www.treas.gov/offices/enforcement/ofac/civpen/penalties/aero_vaca.pdf
WSR Corporation Settles Allegations of a Violation of the Iranian Transactions
Regulations: WSR Corporation (“WSR”), of Chicago, Illinois, has remitted $1,024.80
to settle an allegation of a violation of the Iranian Transactions Regulations. OFAC
alleged that on or about June 6, 2006, WSR attempted to facilitate a trade-related
transaction with Iran on behalf of a non-U.S. person without an OFAC license. WSR did
not voluntarily disclose this matter to OFAC.
Pala International Inc. Settles Burmese Sanctions Regulations Allegations: Pala
International Inc. (“Pala”), of Fallbrook, California has remitted $845.85 to settle
allegations of violations of the Burmese Sanctions Regulations. OFAC alleged that on or
about July 13, 2004, Pala sent a funds transfer to Burma, via an account at a Burmese
Specially Designated National, without an OFAC license. Pala did not voluntarily
disclose this matter to OFAC.
INDIVIDUALS – 31 CFR 501.805(d)(1)(ii)
One individual was assessed a penalty totaling $550 for attempting to violate the
prohibitions in the Iranian Transactions Regulations: On or about May 22, 2006, the
individual attempted to transfer funds to an entity in a third country in order to pay a debt
of an entity in Iran.
One individual has agreed to a settlement totaling $1,000 for allegedly dealing in
property in which Cuba or a Cuban national had an interest: Between December
2004 and July 2005, the individual allegedly purchased Cuban-origin cigars offered for
sale on the Internet. The individual did not voluntarily disclose this matter to OFAC.
One individual has agreed to a settlement totaling $952.25 for allegedly dealing in
property in which Cuba or a Cuban national had an interest: Between July 2003 and
March 2004, the individual allegedly purchased, on four occasions, Cuban-origin cigars
offered for sale on the Internet. The individual did not voluntarily disclose this matter to
OFAC.
For more information regarding OFAC regulations, please go to:
http://www.treas.gov/offices/enforcement/ofac/legal/.

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