Apollo Aviation Group, LLC — $210,600 OFAC penalty
OFAC published a $210,600 civil penalty against Apollo Aviation Group, LLC on 11/07/2019. It is the #182 largest action in OFAC’s 1,052-entry enforcement chart and #17 of the 22 actions published that year.
The record
| Entity, as published by OFAC | Apollo Aviation Group, LLC |
|---|---|
| Penalty / settlement amount | $210,600 |
| Date published by OFAC | 11/07/2019 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #182 of 1,052 |
| Rank within 2019 | #17 of 22 |
| Share of 2019 penalty total | 0.0% |
| Apparent violations cited | 12 |
| Statutory maximum penalty | $3,000,000 |
| Base penalty | $360,000 |
| Voluntarily self-disclosed | Yes |
| OFAC egregiousness determination | Non-egregious |
| Sanctions programs named in the release | Sudan |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $3,000,000. The settled amount of $210,600 is 7.0% of that maximum, which OFAC's Enforcement Guidelines tie to factors including voluntary self-disclosure and whether the conduct was egregious.
Primary source
OFAC enforcement release: 20191107_apollo.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2019 actions
- Hotel Beds — $222,705
- Allianz Global Risks U.S. Insurance Company — $170,535
- Expedia — $325,406
- Atradius Trade Credit Insurance, Inc. — $345,315
- Haverly Systems — $75,375
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