The transaction took place although Ericsson`s compliance department expressly warned that “the delivery of such a satellite platform to Sudan would be contrary to Ericsson`s internal sanctions compliance policy,” according to the settlement agreement. The U.S. Department of the Treasury`s Office of Foreign Assets Control (OFAC) today announced a comparison with Whitford Worldwide Company, LLC (“Whitford”) for $824,314. Whitford, a kitchenware coatings manufacturer based in Elverson, Pennsylvania, has agreed to settle potential civil liability for 74 obvious whitfords and sanctions regulations by Whitford and its subsidiaries in Italy and Turkey. In concrete terms, between November 2012 and December 2015, these subsidiaries sold coatings for customers in Iran and carried out other commercial transactions with Iran. In addition, Whitford`s U.S. employees facilitated some of these transactions with Iran. OFAC found that Whitford voluntarily disclosed the overt violations and that the overt violations are a non-monstrous case. Following the discovery of the misconduct of Anite employees, Keysight conducted a wide-ranging internal investigation to determine the extent of the overt violations, terminate the employees involved and disclose the obvious violations to OFAC and its SEC bids.
In this case, this self-reporting has significantly reduced Keysight`s monetary liability. OFAC has a set of guidelines to impose the sanctions they use to determine how they will enforce the violation of U.S. sanctions. Under these guidelines, self-reporting of a clear offence can reduce the civilian base amount by half of the current legal limit. Beyond self-certification, OFAC took into account the following aggravating and mitigating factors when negotiating the amount of the transaction. On September 27, 2020, the Office of Foreign Assets Control (OFAC) of the Ministry of Finance announced that California-based Keysight Technologies Inc. (Keysight) has promised, on behalf of its former Finnish subsidiary Anite Finland Oy (Anite), the payment of $473,157 to settle possible civil liability for the re-export to Iran of U.S.-controlled meters. As part of this comparison, Keysight also expressed its readiness to define and maintain several sanctions compliance measures aimed at minimizing the risk of similar behaviour re-emerging in the future.
Anite was a subsidiary of Keysight when the obvious infringements appeared in 2016, but Anite was merged with Keysight and no longer exists as a separate entity.