PanAmerican Seed Company has agreed to pay $4.3m in settlement of its potential civil liability for violations of US sanctions on Iran. Between May 2009 and March 2012, it is said to have exported seeds, primarily of flowers, to 2 Iranian distributors on 48 occasions.
OFAC said that PanAm Seed did not voluntarily disclose the alleged violations, and that they constituted an egregious case. Although it found PanAm’s conduct to have been mitigated by the fact that the exports were likely to have been eligible for an OFAC licence, it noted several aggravating factors including that multiple mid-level managers knew of the conduct, it ignored its compliance responsibilities in spite of its high volume of international sales, and it did not initially cooperate with OFAC’s investigation. OFAC’s enforcement notice is here.