The Office of Foreign Assets Control (“OFAC”) today fined a company a whopping $4,320,000 for selling things to Iran. Oh wow, you say, this must have been some really bad stuff like, say, high-powered computers or drones, right? Yep, really dangerous stuff — flower seeds. As in, the things you bury in your backyard and hope sprout up as zinnias.

Well, okay, so maybe they didn’t sell anything dangerous. The company, which is PanAmerican Seed in Illinois, must have sold like a billion dollars worth of seeds, right? Um, we don’t know the value of the seeds. For some reason OFAC won’t say. This is odd because OFAC almost always says what the value of the shipments was. OFAC does say something surpassingly strange about the dollars involved, something it’s never said before. In aggravating factor 4, OFAC says this:

PanAm Seed engaged in this pattern of conduct over a period of years, providing over $770,000 in economic benefit to Iran.

Now this is definitively not the value of the shipment. If $770,000 was the price of the exported goods, then PanAmerican which, presumably, was paid for the seeds by people in Iran, got the $770,000 benefit, or at least however much of that price represented its profit. I suppose this means the profit Iranians made after planting the seeds and selling the flowers, although how OFAC figured that out is rather hard to discern. And if the profits made by Iranian on the seeds is the economic benefit to Iran, then the value of the shipments had to be well south of that figure.

Why OFAC would go to such length to obfuscate the value of the shipments is unclear. Leaving aside that we are talking about petunia seeds here, PanAmerican Seed, at least if OFAC is to be believed, did not behave well. Apparently, it knew what it was doing; it concealed the ultimate destination of the shipments; it refused to cooperate with OFAC when it was turned in; and it apparently provided “inaccurate, misleading, or incomplete” information to OFAC

In any event, it still seems that OFAC has better things to do than to tiptoe through the tulips in Tehran.

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