In May, the US Court of Appeals for the District of Columbia issued a rare ruling reversing in part monetary penalties issued by the Department of Treasury’s Office of Foreign Assets Control (OFAC) against California-based automotive electronics supplier Epsilon Electronics Inc. (Epsilon). OFAC issued a Penalty Notice to Epsilon in July 2014 assessing total monetary penalties of US$4,073,000 from 39 exports to Dubai-based distributor Asra International Corporation LLC (Asra) between 2008 and 2012. According to the Penalty Notice, those exports to Asra violated § 560.204 of the Iranian Transactions and Sanctions Regulations (ITSR, 31 C.F.R. part 560) because they were undertaken with knowledge or reason to know that the goods were intended specifically for export to Iran.
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