OFAC SETTLEMENT WITH ANIMAL NUTRITION COMPANY OVER ALLEGED VIOLATIONS OF CUBAN SANCTIONS

On 6 May, OFAC announced that BIOMIN America Inc, an animal nutrition company based in Kansas, has agreed to pay $257,862 to settle its potential civil liability for coordinating sales of agricultural commodities to a company in Cuba without authorization from OFAC 2012-17.  Believing that BIOMIN America could not directly export its agricultural products to Cuba, and in order to secure a sales opportunity with Alfarma in Cuba, BIOMIN America’s managers developed a transaction structure that they incorrectly determined would be consistent with US sanctions requirements.  The statutory maximum civil monetary penalty applicable in this matter is $2,149,230 but OFAC determined that BIOMIN America voluntarily self-disclosed the apparent violations and that the they constitute a non-egregious case.

https://www.treasury.gov/resource-center/sanctions/CivPen/Documents/20200506_biomin.pdf

https://content.govdelivery.com/accounts/USTREAS/bulletins/28a31b6

 

 

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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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