Financial Sanctions and Enforcement in Dominica: OFAC Slaps Violation on Maritime Registry for Iranian Transactions
The Office of Foreign Assets Control (OFAC) has issued a Finding of Violation to Dominica Maritime Registry, Inc., a company based in Fairhaven, Massachusetts, for violating the Iranian Transactions and Sanctions Regulations.
Background
The violation occurred when Dominica Maritime Registry Inc. executed a Memorandum of Understanding with the National Iranian Tanker Company (NITC) on July 4, 2015. NITC is an entity identified by OFAC as being owned or controlled by the Government of Iran.
The Violation
According to OFAC’s determination, Dominica Maritime Registry Inc. engaged in dealings with a blocked person, which is prohibited under Section 560.211 of the Iranian Transactions and Sanctions Regulations. The company executed a Memorandum of Understanding that was deemed a contingent contract and therefore property in which NITC had an interest.
Consequences
The Finding of Violation highlights the importance of compliance with financial sanctions and regulations to avoid potential penalties and reputational damage. This incident serves as a reminder to all entities operating in Dominica and beyond to be vigilant in their dealings and ensure that they are not inadvertently violating US sanctions laws.
Lessons Learned
- The need for strict adherence to financial regulations in the region
- The importance of conducting thorough due diligence on business partners and counterparties
- The potential consequences of non-compliance with financial sanctions laws
What’s Next?
The full extent of the violation and any subsequent penalties imposed by OFAC remain to be seen. However, this incident underscores the need for entities operating in Dominica and beyond to prioritize compliance with financial regulations and avoid potential violations.