On February 4, 2016, Johnson and Johnson (Middle East) Inc. (JJME), a U.S. company headquartered in New Jersey, received a Finding of Violation from OFAC related to the Sudanese Sanctions Regulations. The Finding of Violation stems from JJME's supervision of Johnson and Johnson Egypt, which conducted five shipments to Sudan in 2010 totaling $227,818. JJME's manager at the time of the transactions was unfamiliar with U.S. sanctions and had not yet received compliance training.
JJME was not penalized for the apparent violations. In reaching this resolution, OFAC considered the following aggravating factors: (1) JJME acted with reckless disregard for U.S. sanctions by conducting exports to Sudan after becoming aware of restrictions; (2) JJME's General Manager was directly involved in the conduct; (3) JJME is part of a large sophisticated corporation; and (4) JJME's compliance program did not provide training on OFAC regulations for its general manager. OFAC also considered the following as mitigating factors: (1) JJME took remedial action; (2) the exports were consumer hygiene products and therefore posed limited harm to U.S. sanctions objectives; (3) JJME had no prior sanctions history in the previous five years; and (4) JJME cooperated extensively with OFAC in the investigation.
For additional information, see the OFAC enforcement notice and Finding of Violation.
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