Sanctions Evasion Reference

C.H. Robinson: five subsidiaries not yet on the parent's screening

A Minnesota logistics company paid OFAC $257,690 in 2024 after five acquired foreign subsidiaries brokered or moved 82 shipments to or from Iran, or of Iranian or Cuban goods, on systems the parent had not yet connected.

period

2018–2024

outcome

Settlement

parties

C.H. Robinson International Inc.

programmes

Islamic Republic of Iran, Cuba

reviewed

2026-09-20

Cite this page
APA 7 
Sanctions Evasion Reference. (2026, September 20). C.H. Robinson: five subsidiaries not yet on the parent's screening. https://sanctionsevasion.org/cases/ch-robinson-subsidiaries-2024/
Chicago 
Sanctions Evasion Reference. “C.H. Robinson: five subsidiaries not yet on the parent's screening.” Last reviewed September 20, 2026. https://sanctionsevasion.org/cases/ch-robinson-subsidiaries-2024/.
BibTeX 
@misc{ser-cases-ch-robinson-subsidiaries-2024,
  author = {{Sanctions Evasion Reference}},
  title  = {C.H. Robinson: five subsidiaries not yet on the parent's screening},
  year   = {2026},
  note   = {Last reviewed 2026-09-20},
  url    = {https://sanctionsevasion.org/cases/ch-robinson-subsidiaries-2024/}
}

The date is when this page was last reviewed, not when it was first published.

Penalties imposed

AuthorityDate AmountNote
OFAC 2024-12-13 $257,690 82 shipments, 76 apparent violations of the Iran regulations and the rest of the Cuba regulations; voluntarily self-disclosed, non-egregious. Base penalty $322,112.

A freight forwarder’s case: the shipments were ordinary, and the sanctions check was in the wrong place.

What happened

Between November 2018 and February 2022, OFAC says, five foreign subsidiaries of C.H. Robinson brokered or carried 82 shipments involving Iran, or Iranian- or Cuban-origin goods, or an Iranian airline. Foreign subsidiaries of US companies can be caught by the Iran and Cuba regulations.

  • China. A shipment from China to Turkey in September 2021 showed on its air waybill the first carrier as “W5”, the code for Mahan Airlines, and the first destination as Tehran. Staff reviewed the waybill and did not recognise either.
  • Spain. A subsidiary acquired in February 2019 sent textile-machinery spare parts to Iran in March 2019, using its own export system, which the parent could not yet see.
  • Canada. 71 shipments to Canada of Iranian- or Cuban-origin goods, worth $448,731, mainly consumer items.
  • Australia. Eight customs-broker entries for Iranian-origin goods worth $148,196.
  • Peru. One export to Iran worth $74,919 in December 2019, which OFAC says an employee arranged by circumventing internal processes. The employee has left.

Why

The release says the “vast majority” happened because the subsidiaries’ systems had not yet been integrated into the parent’s, which had sanctions checks built in. The subsidiaries were bought between 2016 and 2019 and kept their own systems until at least 2022. The parent’s export compliance team found the shipments in routine sample audits in 2022.

The penalty

Voluntarily self-disclosed and non-egregious, so the base was half the transaction value, $322,112, and the settlement was $257,690. OFAC still listed as aggravating that the conduct continued up to 4.5 years after acquisition and that the shipment documents showing Iranian or Cuban origin were available throughout.

What the record shows

  • Integration is a sanctions control. The gap was the time between buying a business and connecting it to the checks.
  • The information was on the paperwork. An air waybill named an Iranian airline and Tehran.

See professional enablers and the Toll Holdings case.

Techniques this case demonstrates

Programmes and jurisdictions in this case

  • Iran sanctions — A layered set of US, EU and UN measures dating from 1979 and substantially rebuilt after 2018, covering energy, finance, shipping, and proliferation-related procurement.
  • Cuba sanctions — The oldest US embargo still administered by OFAC: the Cuban Assets Control Regulations of 1963, layered with later statutes, that prohibit most transactions involving Cuba or its nationals unless licensed.

Enforcement documents and sources

  1. Enforcement release: C.H. Robinson International Inc. Settles with OFAC for $257,690. U.S. Department of the Treasury, Office of Foreign Assets Control, 2024. Enforcement release, 2024-12-13, US$257,690.
  2. Economic Sanctions Enforcement Guidelines, Appendix A to 31 CFR Part 501. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026. Sections I (definitions), II (responses), III (general factors), V.B (penalty calculation).

All enforcement cases