Whitford Worldwide Company, LLC — $824,314 OFAC penalty
OFAC published a $824,314 civil penalty against Whitford Worldwide Company, LLC on 07/28/2020. It is the #112 largest action in OFAC’s 1,052-entry enforcement chart and #6 of the 15 actions published that year.
The record
| Entity, as published by OFAC | Whitford Worldwide Company, LLC |
|---|---|
| Penalty / settlement amount | $824,314 |
| Date published by OFAC | 07/28/2020 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #112 of 1,052 |
| Rank within 2020 | #6 of 15 |
| Share of 2020 penalty total | 3.5% |
| Statutory maximum penalty | $19,953,513 |
| Base penalty | $1,526,508 |
| Voluntarily self-disclosed | Yes |
| OFAC egregiousness determination | Non-egregious |
| Sanctions programs named in the release | Iran, Syria |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $19,953,513. The settled amount of $824,314 is 4.1% 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: 20200728_whitford.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2020 actions
- Comtech Telecommunications Corp. — $894,111
- Essentra FZE Company Limited — $665,112
- National Commercial Bank — $653,347
- Deutsche Bank Trust Company Americas — $583,100
- Eagle Shipping International (USA) LLC — $1,125,000
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