New York-based lobbying firm Park Strategies has paid $12,150 to settle its potential civil liability for apparent violations of the Global Terrorism Sanctions Regulations, the Department of the Treasury’s Office of Foreign Assets Control announced Tuesday.

While the settlement total is relatively minor compared to most enforcement actions, the penalty could have been much larger given the way in which the alleged violations were carried out.

According to OFAC, Park Strategies entered a contract with Al-Barakaat Group of Companies Somalia Ltd. in August 2017. Al-Barakaat was added to OFAC’s Specially Designated Nationals (SDN) List in 2001 and categorized as a global terrorist group.

The contract between Park Strategies and Al-Barakaat called for Park Strategies to receive three separate payments of $10,000 from Al-Barakaat on the first of each month for a period of three months, totaling $30,000, OFAC explains. Park Strategies received the first payment of $10,000 on Sept. 6, 2017, and began performing lobbying services under the contract.

On Oct. 12, 2017, Park Strategies contacted its financial institution to get the Sept. 6 payment placed in a blocked account, asked its external counsel to begin an investigation, halted all work done under the contract, and reported the potential violations to OFAC, the web notice of the settlement details.

Though Park Strategies’ response to the potential violations was swift, an aggravating factor in the case was that the company’s executives had knowledge of and participated in the contract with Al-Barakaat. Park Strategies’ executive vice president and managing director signed the contract, and the executives had “actual knowledge of Al-Barakaat’s SDGT status,” according to OFAC.

In determining the settlement value, OFAC considered that Park Strategies had not received any notice of OFAC infractions in the five years prior to the apparent violations and that the company voluntarily took remedial measures, including suspending work under the contract, blocking the initial payment, reporting the potential infraction to OFAC, and adopting new OFAC screening procedures in the aftermath.

The statutory maximum civil monetary penalty applicable in the matter was $302,584. OFAC determined the apparent violations to be “non-egregious.”

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Kyle Brasseur is Editor in Chief of Compliance Week. His background includes expertise in user personalization with ESPN.com.

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