- 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.