On 17 August, OFAC fined Blue Sky Blue Sea $518k for Iran sanctions.
- DBA: American Export Lines (AEL) and International Shipping Company (USA).
- For 140 apparent violations of Iranian Transactions and Sanctions Regulations.
- By shipping of used and junked cars and parts from US via Iran to Afghanistan.
Sanction Factors
- Firm showed reckless disregard for US sanctions, by not using minimal caution.
- AEL President and co-owner knew and approved of the transshipments via Iran.
- Provided economic benefits to Iran, by conduct and the volume of transactions.
- AEL is international freight forwarder with experience with US, OFAC regulation.
- In mitigation, goods were transshipped through Iran and had no end use there.
- Did have a compliance program in place, but silent on transshipments via Iran
