The Treasury Department’s Office of Foreign Assets Control (“OFAC”) released today its monthly summary of enforcement actions. It would appear that the OFAC Task Force devoted to crushing sales of Cuban stogies on the Internets was either on vacation or disbanded because this is the first month where some hapless Internaut wasn’t fined a couple of hundred dollars for snagging a few boxes of Cuban Cohibas on-line. Or perhaps the Task Force was assigned to Iranian caviar given the circumstances surrounding the penalty paid by Diversified Business Communications.

Diversified organizes trade shows and conferences, including the annual European Seafood Exposition in Brussels. Sometime after 2000 (the Penalty Notice doesn’t specify a precise date), Diversified sold booth space to Shilat Trading Company, the Iranian company charged with sales and distribution of Iranian caviar.

In it’s defense, Diversified argued to OFAC that on March 17, 2000, the Secretary of State announced that sanctions against Iran would be eased to allow U.S. persons to purchase and import carpets and food products, such as dried fruits, nuts, and caviar from Iran, citing 31 C.F.R. §§ 560.534 and 560.535, which authorize the trade in, among other things, “foodstuffs intended for human consumption.” Diversified also argued that “Shilat is the exclusive producer of Iran’s caviar, which appears to be a primary focus of this exemption.”

OFAC’s response was, in short, that you can’t eat a trade show booth:

Company does not allege to [sic] have purchased foodstuffs from Shilat. Moreover, Company has not denied its provision of services, in the form of booth space booking arrangements, at an annual European seafood exposition, to Shilat, an entity located in Iran.

Because Diversified took steps to keep Shilat from participating in future European Seafood Expositions, OFAC whacked the possible penalty in half, down to $5,500. That’s enough, by the way, to buy about two pounds of Iranian Beluga Caviar at retail.

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