US-based cookware coating manufacturer Whitford Worldwide Company will be paying $824,314 as settlement money for violating the Iran sanctions program of the US Office of Foreign Assets Control (OFAC). Whitford’s foreign subsidiaries in Italy and Turkey did not heed the updates to OFAC’s Iran sanctions program that prohibited them from selling coatings to Iran.
Whitford did not ensure compliance with the rules regulating transactions with a high-risk jurisdiction like Iran. Moreover, the company invoked indirect channels to help its foreign subsidiaries continue selling to Iran once it was warned about the issues with the foreign subsidiary sales to Iran. Consequently, Whitford allowed 74 prohibited transactions, providing Iran an economic benefit of $3.05 million. All these violations occurred during 2012-15, after the amendments to OFAC’s Iran sanctions program in 2012 banned US-owned or US-controlled foreign companies from conducting transactions with Iran.
When deciding the settlement amount, OFAC did not ignore Whitford’s remedial measures in response to the violations of US sanctions. Whitford readily helped OFAC with its investigation. The company also conducted an internal investigation and disclosed to OFAC all the transactions that were in violation of the sanctions. Whitford also appointed independent external as well as internal compliance monitors. In addition, the company promptly altered its leadership, by removing the Chief Executive Officer from the Board of Directors.