OFAC SETTLES WITH TOLL HOLDINGS FOR $6,131,855 FOR APPARENT SANCTIONS VIOLATIONS
March 23, 2022
On April 25, 2022, OFAC issued an Enforcement Release announcing its settlement with Toll Holdings Limited (“Toll”), an international freight forwarding and logistics company headquartered in Australia, for alleged violations of multiple OFAC sanctions programs. Toll allegedly originated or caused to be received 2,958 payments in connection with sea, air, and rail shipments conducted by Toll, its affiliates, or providers and suppliers to, from, or through North Korea, Iran, or Syria, and/or involving the property or interests in property of an entity on OFAC’s SDN List between approximately January 2013 and February 2019. Further, according to OFAC, the value of the payments related to a designated person or made in connection with a sanctioned country totaled about $48,409,909 and were processed through at least four financial institutions in the U.S. or foreign branches of financial institutions incorporated in the U.S., which is in violation of OFAC sanctions. Of the payments, 424 involved Mahan Airlines, which was designated pursuant to Executive Order (“E.O.”) 132241, and Hafiz Darya Shipping Lines Company, which was designated pursuant to E.O. 138822, with the remainder of the transactions, including 2,534 funds transfers, comprising payments made for shipments to, from, or transshipping through North Korea, Iran, or Syria. According to OFAC, the statutory maximum civil monetary penalty applicable in this matter was $826,431,378, but since OFAC determined that Toll’s apparent violations were non-egregious and since Toll voluntarily self-disclosed the alleged violations, OFAC agreed to settle Toll’s potential civil liability to $6,131,855.
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