On 6th August, OFAC announced a settlement with US company PACCAR Inc and involving its Dutch subsidiary, DAF Trucks N.V.  In 2013-2015 DAF sold or supplied 63 trucks, worth around $5 million, to customers in Europe that it knew or had reason to know were ultimately intended for buyers in Iran.  PACCAR voluntarily disclosed the apparent violations, and OFAC considered that the apparent violations constitute a non-egregious case.  The measures that have been taken by the companies include DAF hiring a full-time Compliance Director who reports to DAF’s General Counsel and Chief Compliance Officer, and DAF having sent a letter to all dealers in its dealer network reminding them of their obligations to comply with U.S. and other trade sanctions and received certifications from each of its dealers regarding their compliance with all applicable trade sanctions.  The base penalty amount for the apparent violations is $2,713,214.

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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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