The Treasury Department’s Office of Foreign Assets Control (OFAC) reached a $4,320,000 civil settlement with PanAmerican Seed Company (PanAm Seed) for alleged violations of the Iranian Transactions and Sanctions Regulations (ITSR) that occurred between 2009 and 2012. OFAC treated this as an “egregious case,” which may raise eyebrows because it involved the export of seeds, primarily for flowers, which is not a focus of US national security concerns related to Iran. OFAC says that it likely would have granted licenses for these shipments had the company applied for them. This case demonstrates that the process of resolving a case with OFAC is a factor to keep in mind that can impact the settlement, along with the agency’s assessment of the underlying conduct itself. Companies operating in less sensitive fields such as agriculture, food, and medicine should not discount the importance of maintaining a sanctions compliance program and responding prudently to any inquiries from OFAC. See our advisory for more detail.
