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Cosmetics company violated OFAC’s North Korea sanctions

By Richard L. Cassin | Friday, February 1, 2019 at 9:28AM

Image courtesy of ELFThe Treasury Department’s Office of Foreign Assets Control fined a California-based cosmetics company nearly $1 million for importing fake eyelash kits that contained materials from North Korea.

The imports by e.l.f. Cosmetics, Inc. (or ELF) violated OFAC’s North Korea Sanctions Regulations.

ELF found the North Korea-sourced materials in 156 shipments of false eyelash kits that it bought from two suppliers in China. The total value of the tainted shipments was $4.4 million.

“Throughout the time period in which the apparent violations occurred, ELF’s OFAC compliance program was either non-existent or inadequate,” OFAC said.

About 80 percent of the false eyelash kits ELF bought from the two China-based suppliers contained materials from North Korea, OFAC said.

ELF could have been fined $40 million for the violations, OFAC said.

The fine was reduced to about $996,000 because ELF self disclosed the violations, cooperated with OFAC, and adopted an enhanced compliance program.

OFAC also said no one at ELF knew about the North Korea content, and the fake eyelash kits weren’t a big part of ELF’s business.

OFAC’s January 31, 2019 Enforcement Information against e.l.f. Cosmetics, Inc. is here (pdf).

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Richard L. Cassin is editor at large of the FCPA Blog.