A cosmetics company agreed to settle U.S. Treasury ("Treasury") Office of Foreign Assets Control ("OFAC") charges that it violated the North Korea Sanctions Regulations.
According to OFAC, e.l.f. Cosmetics, Inc. ("ELF") imported over $4 million worth of "false eyelash kits from two suppliers located in the People's Republic of China" that sourced materials from North Korea. OFAC noted that ELF's sanctions compliance program was insufficient or nonexistent at the time of the apparent violations. However, ELF personnel did not have actual knowledge of the suppliers' conduct, and the company self-disclosed its apparent violations and cooperated with OFAC's investigation. In light of these circumstances, the case was deemed "non-egregious."
To settle the charges, ELF agreed to pay over $996,080. ELF also stated that it had terminated the conduct that led to the apparent violations, and the company undertook steps to lower the risk of recurrence of similar conduct in the future, including with enhanced supply chain audits, supplier certifications and training.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
