Construction Specialties Inc. — $660,954 OFAC penalty
OFAC published a $660,954 civil penalty against Construction Specialties Inc. on 08/16/2023. It is the #121 largest action in OFAC’s 1,052-entry enforcement chart and #11 of the 16 actions published that year.
What OFAC said
Settles with Construction Specialties Inc. for $660,594 Related to Apparent Violations of the Iranian Transactions and Sanctions Regulations Construction Specialties Inc. ("CS"), a company headquartered in New Jersey that sells specialized building materials, has agreed to pay $660,594 to settle its subsidiary's potential civil liability for three apparent violations of OFAC sanctions on Iran.
Quoted verbatim from OFAC’s enforcement release — read the original.
The record
| Entity, as published by OFAC | Construction Specialties Inc. |
|---|---|
| Penalty / settlement amount | $660,954 |
| Date published by OFAC | 08/16/2023 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #121 of 1,052 |
| Rank within 2023 | #11 of 16 |
| Share of 2023 penalty total | 0.0% |
| Statutory maximum penalty | $2,201,982 |
| Base penalty | $1,100,991 |
| Voluntarily self-disclosed | Yes |
| OFAC egregiousness determination | Egregious |
| Sanctions programs named in the release | Iran |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $2,201,982. The settled amount of $660,954 is 30.0% 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: 20230816_csme.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2023 actions
- Privilege Underwriters Reciprocal Exchange — $466,200
- Godfrey Phillips India Limited — $332,500
- DaVinci Payments — $206,213
- CoinList Markets LLC — $1,207,830
- Uphold HQ Inc. — $72,230.32
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