The Treasury Department’s Office of Foreign Assets Control (OFAC) on Wednesday announced that a Geneva, Switzerland-based airlines systems company will pay a $7,829,640 fine for violating U.S. sanctions.
Between April 2013 and February 2018, Société Internationale de Télécommunications Aéronautiques (SITA) committed 9,256 violations of the Global Terrorism Sanctions Regulations by providing commercial telecommunications network and information technology services to airlines on the OFAC’s Specially Designated Nationals and Blocked Persons (SDN) List.
U.S. individuals and companies are generally prohibited from conducting business with individuals or entities on the SDN List. Additionally, any entities owned 50% or more in the aggregate by these listed individuals or entities are blocked.
SITA provides IT services that cover an airline’s passenger, baggage and cargo reservations; flight planning and dispatch; border management services; and messaging. Some of these services are developed and provided through SITA’s U.S. operation.
SITA serviced SDN-listed airlines, including Iran’s Mahan Air, Syrian Arab Airlines, Caspian Air, Meraj Air and Al-Naser Airlines.
“These services and software were subject to U.S. jurisdiction because they were provided from, or transited through, the United States or involved the provision of U.S.-origin software with knowledge that customers designated as SDGTs (specially designated global terrorists) would benefit from use of that software,” OFAC said in its enforcement statement.
SITA could have been assessed a $13,384,000 fine, but OFAC said it took into account various mitigating factors, including “the transactions giving rise to the apparent violations represented a small percentage of SITA’s overall business” and the company implemented immediate enhancements to its compliance program and cooperated with OFAC’s investigation.
In addition, SITA appointed a global head of ethics and compliance and requires sanctions compliance training for all new employees and annual follow-up training for existing employees.
“This enforcement action highlights the benefits companies operating in high-risk industries can realize by implementing effective, thorough, and ongoing risk-based compliance measures, especially when engaging in transactions concerning the aviation industry,” OFAC said.
In recent years, the U.S. government has taken aim at sanctioning aviation operations and assets in Iran and Syria, noting that the airlines help facilitate the regimes’ alleged terrorist activities in the Middle East.