Godfrey Phillips settles with OFAC

OFAC has reached a $332,500 settlement with Godfrey Phillips India Limited ("GPI"). GPI, a Mumbai, India-registered tobacco company, has agreed to settle its potential civil liability for five apparent violations of the North Korea Sanctions Regulations, 31 C.F.R. part 510. Specifically, between July and August 2017, GPI requested payment in U.S. dollars for its indirect exportation of tobacco to the Democratic People’s Republic of Korea. One of these five payments was directed to the foreign branch of a U.S. financial institution. OFAC determined that GPI did not voluntarily self-disclose the apparent violations, and that the apparent violations constitute a non-egregious case.

From the Enforcement Notice linked above: "By directing the Hong Kong Intermediaries to remit payments in USD, GPI caused U.S. correspondent banks that processed payments, as well as the foreign branch of a U.S. bank, to export financial services to or otherwise facilitate the exportation of tobacco to the DPRK. Accordingly, GPI appears to have violated § 510.212 of the [North Korea Sanctions Regulations], 31 C.F.R. part 510, when it caused U.S. banks to apparently violate §§ 510.206 and 510.211 of the NKSR (the 'Apparent Violations')."