The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $334,800 settlement with Richemont North America, Inc., d.b.a. Cartier (“Richemont”), headquartered in New York, New York, to settle Richemont's potential civil liability for four apparent violations of the Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. Part 598 (FNKSR). Between the approximate dates of October 5, 2010 and April 21, 2011, Richemont appears to have violated § 598.203 of the FNKSR when it exported four shipments of jewelry to Shuen Wai Holding Limited in Hong Kong (“Shuen Wai”), an entity OFAC added to the List of Specially Designated Nationals and Blocked Persons on November 13, 2008. OFAC determined that Richemont did not voluntarily self-disclose the apparent violations to OFAC, and that the apparent violations constitute a non-egregious case.
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