There appears to be no OFAC certification in this instance.  There's Henry
Johnson's warranty that JM Chemicals is in compliance with OFAC (p. 25 of
the complaint).  There's no reason to think that JMC was in violation of
OFAC by trading with an enemy of the US.  Presumably what fraud there is
would go back to the individuals named in the lawsuit and countersuit
rather than a shell company.

Eric


On Sun, Aug 28, 2016 at 11:16 PM, Axil Axil <janap...@gmail.com> wrote:

> True, the IH/Rossi contrace is contingent upon te certification of the
> customer. It would be stupid to misrepresent this certication, but anything
> is possible if improbable. Such misrepresentation is a criminal offence.
>
> *How much are the fines for violating these regulations?*
> The fines for violations can be substantial. Depending on the program,
> criminal penalties for willful violations can include fines ranging up to
> $20 million and imprisonment of up to 30 years. Civil penalties for
> violations of the Trading With the Enemy Act can range up to $65,000 for
> each violation. Civil penalties for violations of the International
> Emergency Economic Powers Act can range up to $250,000 or twice the amount
> of the underlying transaction for each violation. Civil penalties for
> violations of the Foreign Narcotics Kingpin Designation Act can range up to
> $1,075,000 for each violation. [10-08-13]
>
> On Sun, Aug 28, 2016 at 11:41 PM, Eric Walker <eric.wal...@gmail.com>
> wrote:
>
>> On Sun, Aug 28, 2016 at 9:35 PM, Axil Axil <janap...@gmail.com> wrote:
>>
>> How could a fraudulent company pass through the OFAC certication process?
>>>
>>
>> How could one conclude that JM obtained OFAC certification?  We go
>> through this again.
>>
>> Eric
>>
>>
>

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