OFAC settles with Kollmorgen & designates its Turkish MD for directing the violation

Last week (7 February), OFAC reached a $13,381 settlement with Kollmorgen Corporation to settle potential civil liability on behalf of its Turkish affiliate, Elsim Elektroteknik Sistemler Sanayi ve Ticaret Anonim Sirketi, for 6 apparent violations of the Iranian Transactions and Sanctions Regulations. On 6 occasions between July 2013 and July 2015, Elsim is said to have serviced machines containing Elsim products located in Iran and provided products, parts, or services valued $14,867 with knowledge that they were destined for Iranian end-users. See OFAC Notice and Treasury Enforcement Information.

OFAC also designated Turkish national Evren Kayakiran as a Foreign Sanctions Evader (FSE), pursuant to Executive Order 13608, for directing Elsim (as its Managing Director) to commit those sanctions violations and for then attempting to conceal them. The FSE List is separate from the SDN List. See OFAC Notice and Treasury Press Release, saying “[t]his is the first time that OFAC has designated an individual as a Foreign Sanctions Evader while resolving an enforcement matter, and is a marked change to how we will counter these acts of deception.”