Small in penalty terms and large in evidentiary value, because OFAC’s enforcement release quotes the instruction directly.
The release describes a 2018 meeting at which a North Korean national asked whether Essentra FZE could manufacture cigarette filter rods for export to North Korea, and records the message the same person later sent to an Essentra employee: not to mention that the customer was in his country, to say China or somewhere else instead, and that the contract would be signed by another foreign company.
What makes this case unusual
Almost every front company case has to establish knowledge by inference — from the improbability of an explanation, from questions asked and abandoned, from the shape of a structure. Here the request to misdescribe the destination and to have a different company sign the contract is in the record, in the counterparty’s own words.
That is why it appears on several technique pages at once. The same short exchange establishes the front company, the third-country routing, and the misrepresentation of the end user.
The financial leg
OFAC records that Essentra FZE received payment for the shipment into its bank accounts at the foreign branch of a US bank, which is what brought the conduct within US jurisdiction. The goods never touched the United States; the dollars did.