The firm settled 48 apparent violations of sanctions on North Korea, Iran, Sudan and Cuba. The violations were voluntarily self-disclosed and were considered non-egregious.
Between 2008 and 2011, the firm issued insurance policies, and paid claims, for North Korean vessels, and covered shipping transactions involving Cuba, Iran and Sudan – all while not having an OFAC compliance program.
The total base penalty for all 48 violations was $755,042 – you can see all the detail in OFAC’s notice. Here’s how you get to $271K:
The following were considered aggravating factors:
- Navigators
managers and supervisors knew or had reason to know that the majority of the insurance policies
and claims payments at issue involved OFAC-sanctioned countries;- Navigators is a
commercially sophisticated financial institution; and- Navigators did not have a formal OFAC
compliance program in place at the time the apparent violations occurred.The following were
considered mitigating factors:
- Navigators has not received a penalty notice or Finding of
Violation from OFAC in the five years preceding the earliest date of the apparent violations;- Navigators took appropriate remedial action in response to the apparent violations, including the
formation and implementation of a comprehensive OFAC compliance program; and- Navigators
cooperated with OFAC’s investigation by providing all information in a responsive, well-
organized fashion, and by signing a tolling agreement and two extensions to that agreement
Link:
Posted with BlogsyFiled under: Cuba Sanctions, Enforcement Actions, Iranian Sanctions, North Korea (DPRK) Sanctions, OFAC Updates, Sudan Sanctions
