AMAZON AGREES TO PAY $134,523 SETTLEMENT FOR ALLEGED SANCTIONS VIOLATIONS
August 24, 2020
On July 8, 2020, the Office of Foreign Assets Control (OFAC) issued a settlement agreement, available here, through which Amazon agreed to pay $134,523 for alleged violations of U.S. sanctions. OFAC alleged that the violations were related to deficiencies in Amazon’s sanctions screening processes, which resulted in Amazon providing goods and services to persons sanctioned by OFAC, to persons located in the sanctioned region or countries of Crimea, Iran, and Syria, and to individuals located in or employed by the foreign missions of countries sanctioned by OFAC. Specifically, OFAC alleges that from on or about November 15, 2011, to on or about October 18, 2018, persons located in Crimea, Iran, and Syria placed orders or otherwise conducted business on Amazon’s websites for consumer and retail goods and services, and also accepted and processed orders on its websites for persons located in or employed by the foreign missions of Cuba, Iran, North Korea, Sudan, and Syria. Amazon is also alleged to have improperly delivered to individuals on OFAC’s List of Specially Designated Nationals and Blocked Persons.
Amazon self-reported the alleged violations after conducting an internal investigation, assisted with OFAC’s own investigation of the transactions, and admitted that the company’s automated sanctions screening procedures had failed to properly detect the transaction. As part of the settlement, Amazon will also undertake remedial measures, including a revamp of its compliance program, introducing additional screening controls, and increasing training for employees.
If you have any questions, please contact Evelyn Sahr (esahr@eckertseamans.com or 202-659-6622); Drew Derco (dderco@eckertseamans.com or 202-659-6665), or Andy Orr (aorr@eckertsemans.com or 202-659-6625).
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