A small settlement that teaches the maritime identifier problem better than any large one.
OFAC’s enforcement information for 2 May 2019 records that between about 18 February and 14 November 2011, MID-SHIP processed five electronic funds transfers totalling approximately $472,861 relating to payments associated with blocked vessels identified on the SDN List. OFAC had designated Islamic Republic of Iran Shipping Lines in September 2008 under the proliferation authority.
The identifier point
Vessels are listed on the SDN List by name and IMO number. Names change; IMO numbers do not.
An agency processing payments for a voyage deals with the vessel as it is currently named on the charter, the bill of lading and the invoice, and screening that name against the list will not match if the ship has since been renamed. Screening the IMO number will.
That single fact is why the maritime advisories put such weight on the IMO number, why designation entries carry it, and why physical alteration of the marking is treated as a strong indicator rather than a clerical matter.
Why the penalty exceeded the transaction value
The five transfers totalled about $472,861 and the settlement was $871,837. OFAC determined the apparent violations were egregious and not voluntarily self-disclosed, and both the statutory maximum and base penalty amounts were $1,490,320.
Sanctions penalties are calculated per violation against a statutory maximum, not as a proportion of the sums involved, which is why small-value conduct can attract penalties well above the amounts transferred.