IPSA International Services, Inc., a US-based risk management firm, has been fined $259,200 by OFAC for violating US sanctions on Iran. The violations, worth $290,784, are said to have occurred when IPSA assisted two countries with their citizenship by investment programmes. Some of the applicants to the programmes were Iranian nationals and, because most of the information about them could not be checked or verified from outside of Iran, IPSA and its subsidiaries engaged subcontractors, who in turn hired third parties, to validate their information. As a result, OFAC found that IPSA had directly imported Iranian-origin services into the United States, or done so indirectly by reviewing, approving, and initiating payments to the providers of the Iranian origin services by its foreign subsidiaries.
The base penalty amount was $720,000 and the maximum penalty available was $18,000,000. In aggravation, OFAC found that IPSA had not voluntarily disclosed the violations, that at least one of its senior management knew or had reason to know of the violations, and that the underlying conduct was not eligible for OFAC authorisation under an existing licence. In mitigation, OFAC said that IPSA had substantially cooperated with its investigation and taken significant remedial measures to prevent further violations from occurring in the future.