OFAC Fines Paper Company For Illegal Exports From Canada

A Connecticut-based paper company, BD White Birch Investment LLC, commonly known as White Birch USA, was fined by the Treasury Department’s Office of Foreign Assets Control (OFAC) for exporting paper from Canada to Sudan.

The company settled the allegations for violating the US trade sanctions for $372,465 despite being “actively involved in discussing, arranging, and executing the export transactions to Sudan.”   OFAC said that White Birch USA recklessly disregarded the requirements for US sanctions and failed to take action to fix the apparent violations.  Further, OFAC discovered that supervisors and managers either knew about the illegal exports or were actively involved by trying to conceal the ultimate destination of the goods from its bank. 

White Birch USA did not have a proper compliance system at the time of the incident.  This caused a series of compliance related issues leading to the OFAC fine.  White Birch USA could have been fined up to $853,000 for not cooperating during the investigation and giving misleading information to OFAC but because it was a “non-egregious case” and the company had no prior OFAC sanction history the fine was reduced.

Although OFAC found no malice in the company’s wrong doing, it was an act of negligence that could have been avoided with a proper compliance system and training.  The company will be implementing an efficient new compliance system, installing new compliance policies, and providing company-wide OFAC compliance training.

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