On 27 July 2017, CSE TransTel Pte. Ltd. (“TransTel”), a wholly-owned subsidiary of the international technology group CSE Global Limited, both of which are located in Singapore, has agreed to pay USD12 million to settle its potential civil liability for 104 apparent violations of the United States (“US“) Iran sanctions regime.
During this investigation, OFAC found that between June 2012 and March 2013, TransTel caused at least six separate financial institutions to engage in the unauthorised exportation or re-exportation of financial services from the US to Iran, a prohibition of § 560.204 of the International Emergency Economic Powers Act and the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560, by originating 104 US Dollar wire transfers involving Iran and totalling more than USD11 million through the US.
OFAC determined that TransTel did not voluntarily self-disclose the apparent violations to OFAC, and that the apparent violations constitute an egregious case.
The full settlement agreement can be found here.