No blushes spared for cosmetics company hit with OFAC falsy fine

A Californian make-up company, e.l.f. Cosmetics, Inc., (‘ELF’) has been hit with a fine of just short of $1m, settling potential civil liability for 156 shipments of false eyelash kits from two suppliers located in the People’s Republic of China that contained materials sourced from North Korea (‘DPRK’), the Office of Foreign Assets Control (‘OFAC’) has said.

OFAC said that ELF ‘imported the false eyelash kits from on or about April 1, 2012 to on or about January 28, 2017. The total value of the shipments equaled $4,427,019.26. Throughout the time period in which the apparent violations occurred, ELF’s OFAC compliance program was either non-existent or inadequate,’ and that the company’s production review efforts ‘focused on quality assurance issues pertaining to the production process, raw materials, and end products of the goods it purchased and/or imported.’

It said that until January 2017, ‘ELF’s compliance program and its supplier audits failed to discover that approximately 80 percent of the false eyelash kits supplied by two of ELF’s China-based suppliers contained materials from the DPRK.’

See:
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20190131.aspx