OFAC Fines Embassy Worker for Violating Kingpin Sanctions

The Office of Foreign Assets Control fined a U.S. person $5,000 for buying jewelry, meals, clothing, hotel rooms and other gifts for a person on the Specially Designated Nationals List. The U.S. person, who OFAC did not name, was a civilian hire stationed by the U.S. Army at the U.S. Embassy in Bogota, Colombia, during the violations, according to an Aug. 11 notice.

While working at the embassy, the U.S. person developed a personal relationship with a specially designated narcotics trafficker, who visited the embassy in 2015 for a meeting on their designation status, OFAC said. After the meeting, the U.S. person was introduced to the narcotics trafficker, it said. They “maintained contact and started a personal relationship,” and the U.S. person bought the narcotics trafficker a series of gifts despite being aware that the trafficker was listed on OFAC’s SDN list. The U.S. person researched online whether the gifts were legal but “did not seek further counseling or advice from the various government and legal resources that were readily available in the embassy or by their employer.”

OFAC said the gifts, which totaled about $3,400, violated the Foreign Narcotics Kingpin Sanctions Regulations. The U.S. person did not voluntarily disclose the violations, which OFAC said constituted an egregious case. Aggravating factors included the U.S. person’s failure to approach OFAC personnel or use resources to “resolve issues arising from forming a new relationship” with a narcotics trafficker. Other aggravating factors included the U.S. person’s knowledge that the trafficker was on the SDN list and the fact that the U.S. person was stationed in a “national security position.” The person also bought gifts for the person on the SDN list as that person sought removal from the list, which “created a perception of impropriety” that could harm “the integrity of government processes,” such as sanctions regimes.

Mitigating factors included the fact that the U.S. person was “relieved of their duties” and received “significant disciplinary action” from the U.S. Army. OFAC also said the person did not have experience with sanctions compliance and added that the gifts were “personal in nature and involve goods with a single, immediate, and one-time use with limited or exhausted secondary value.” OFAC also said the person cooperated with OFAC’s investigation.