The Office of Foreign Assets Control (“OFAC”) recently announced a whopping $1.5 million fine against “Alma Investment LLC, a UAE-based investment and advising company” for violations of U.S. sanctions on Iran. Since the case involved six electronic funds transfers for $103,283, the $1.5 million fine represents the maximum available fine.

One of the reasons for the mega-fine cited by OFAC was that “Alma did not cooperate with OFAC during the course of its investigation.” Reading between the lines, Alma didn’t cooperate because it never responded to or acknowledged OFAC’s requests for information, nor did it consent to the imposition of this fine. That is likely because Alma doesn’t really exist but was an entirely fictional company created as a scheme to defraud investors. The Dubai Financial Services Authority released a warning on Alma indicating Alma was fraudulently soliciting funds from investors and representing that it was registered in Dubai even though, according to DFSA, it was neither registered in Dubai nor present at the address it represented in Dubai. The website for Alma cited by the DFSA is no longer operational. So, I hope OFAC hasn’t spent the $1.5 million yet.

However, I do suggest that the agency take a look at fining Oceanic Airlines to make up the shortfall. It’s rumored that Oceanic just sold a Boeing 777 to Iran Air. And fining Oceanic “will have a compliance/deterrence effect” just as strong, if not stronger, as the one cited by OFAC in levying the $1.5 million fine against Alma.

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