Treasury settles with Wisconsin company over Italian subsidiary’s sales to Iran
The U.S. Treasury Department announced on Wednesday that it had reached a $60,764 settlement with Wisconsin-based Rice Lake Weighing Systems over eight apparent violations of U.S. sanctions on Iran involving its Italian subsidiary, Dini Argeo.
According to the department, Dini Argeo exported weighing equipment to a distributor in the United Arab Emirates between July 2019 and November 2021, knowing the goods would ultimately be reexported to an end user in Iran. Treasury determined that the violations were “voluntarily self-disclosed and non-egregious.”
Rice Lake, which acquired Dini Argeo in 2016, notified the Italian subsidiary in 2018 of changes that made its previous dealings with Iran illegal. However, the department found that the guidance was too general and lacked specific compliance instructions and an Italian translation. Rice Lake also failed to verify that Dini Argeo understood and complied with the restrictions.
Dini Argeo stopped selling directly to Iranian customers after receiving the notice but did “not appear to have understood that selling goods indirectly to Iran was also prohibited,” Treasury said.
Rice Lake launched an internal investigation in 2021 after learning that its products were still being shipped from Italy to an Iranian company and promptly notified the Treasury Department. The agency cited the company’s voluntary disclosure as a factor in the settlement.
Treasury said the case underscores the need for U.S. companies to ensure that foreign subsidiaries have effective, risk-based sanctions controls and that employees, not only management, understand how U.S. sanctions affect their day-to-day operations.
“U.S. companies should ensure their foreign subsidiaries implement effective, risk-based controls to mitigate any sanctions risks,” Treasury said in an enforcement notice. “Misunderstandings can give rise to liability, and enforcement action may be appropriate where reasonable steps were not taken to avoid them.”
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The U.S. Treasury Department announced a $60,764 settlement with Wisconsin-based Rice Lake Weighing Systems for eight apparent violations of U.S. sanctions on Iran. Its Italian subsidiary, Dini Argeo, exported weighing equipment to a UAE distributor between July 2019 and November 2021, knowing the goods would be reexported to Iran. Rice Lake acquired Dini Argeo in 2016 and informed them in 2018 that previous dealings with Iran were now illegal, but the guidance was too general and lacked specific instructions or an Italian translation. Dini Argeo ceased direct sales but "not appear to have understood that selling goods indirectly to Iran was also prohibited." Rice Lake launched an internal investigation in 2021 and voluntarily disclosed the violations, which the Treasury deemed "non-egregious." The Treasury emphasized that "U.S. companies should ensure their foreign subsidiaries implement effective, risk-based controls to mitigate any sanctions risks."
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