OFAC SANCTIONS TURKISH NATIONAL FOR VIOLATION OF IRAN SANCTIONS

On 7th February, OFAC announced that it had designated a Turkey-based individual, Evren Kayakiran, who directed a foreign subsidiary of a US company to violate US sanctions against Iran and then attempted to conceal those violations.  This is said to be the first time OFAC has named an individual a foreign sanctions evader in relation to a civil enforcement action.   The Foreign Sanctions Evaders list (FSE List) is separate from OFAC’s List of Specially Designated Nationals and Blocked Persons (the SDN List), and it identifies foreign individuals and entities that have violated, attempted to violate, conspired to violate, or caused a violation of US sanctions against Iran or Syria.  All transactions or dealings, whether direct or indirect, involving Kayakiran, in or related to any goods, services, or technology in or intended for the US; or any goods, services, or technology provided by or to US persons, wherever located, are prohibited – and US financial institutions must reject payments involving Kayakiran.  In 2013-15, he was the managing director of a Turkish company that imports, distributes, and installs motion control products, and which was acquired by a US company in 2013.  He regularly and fraudulently certified to the US Company that no products or services were being sent to Iran; and it was only after an employee filed an internal complaint with the US company via the company’s ethics hotline in late October 2015 that the violations and associated conduct came to light.

https://home.treasury.gov/news/press-releases/sm606

https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20190207.aspx

Meanwhile –

KOLLMORGEN CORPORATION SETTLES POTENTIAL CIVIL LIABILITY FOR APPARENT VIOLATIONS OF THE IRANIAN TRANSACTIONS AND SANCTIONS REGULATIONS

A release from OFAC detailed the treatment of the company hoodwinked by Kayakiran; and which, on behalf of its Turkish affiliate, Elsim Elektroteknik Sistemler Sanayi ve Ticaret Anonim Sirketi, has paid $13,381 to settle potential civil liability for 6 apparent violations of the Iranian Transactions and Sanctions Regulations.

https://www.treasury.gov/resource-center/sanctions/CivPen/Documents/20190207_kollmorgen.pdf

 

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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