U.S. OFAC Fine HK Jewel Export

On 26 September, OFAC fined exporter for jewelry sales to HK person.

  • Settlement agreement of $344,800 with Richemont North America, DBA. Cartier.
  • Firm violated rules when exporting jewelry shipments to Shuen Wai Holding HK.
  • Shuen Wai is an entity on OFAC list of designated nationals and blocked persons.
  • OFAC determined Richemont did not voluntarily self-disclose apparent violations.

Information on Client

  • individual purchased jewelry in firm's boutiques, located in California or Nevada.
  • Provided Shuen Wai’s name and mail address to Richemont, as the ship-to party.
  • Information and documentation had same name and address, as per the SDN list.
  • However, firm did not identify sanctions issues with trade prior to shipping goods.
  • Failed to exercise minimal degree of caution or care with respect to its conduct.
  • Noted entity has global operations, in industry at high risk for money laundering.

OFAC Impact on Retailers

  • OFAC said case highlighted risk to retail business with international transactions.
  • Specifically, businesses that ship their products directly to customers outside US.
  • OFAC encouraged companies to use risk-based approach to sanctions compliance.
  • By implementing processes and procedures to identify and mitigate areas of risk.
  • Factors to consider are types of products and services, frequency and volume of
    international transactions and shipments, client base, size, geographic locations.