A US person could have been jailed and fined $163,000 for facilitating 19 separate transfers to Iran of medical goods valued at $49,341, but ended up paying only $29,340.  Why the 82 percent discount?  That person’s lawyers convinced OFAC that – even though their client did not self-disclose before getting caught, and indeed continued to break the law after OFAC issued a warning letter – this was a “non-egregious” case because “the goods were medical devices that are potentially licensable by OFAC under existing licensing policy.”

Foresight Point:  As a political matter, the US was probably loathe to hammer a citizen for smoothing the path of  medical supplies to Iran.  But unless you’re the second coming of Mother Teresa, don’t expect such leniency.

And remember, as always:  The cost of defending an enforcement action always exceeds the cost of obtaining approvals that are there for the asking.