The following Compromise Agreement is a true copy
 

of the signed agreement.
 

If you require a copy of a signed agreement(s), please 

contact the Commission’s Office of the Secretary, 

202-523-5725.
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

COMPROMISE AGREEMENT 

FMC File No. 17139 

This Compromise Agreement is entered into between: 

(1) the Federal Maritime Commission (Commission); and 

(2) British Association of Removers Ltd. d/b/a Movers Trading Club (Respondent). 

WHEREAS, the Commission is considering the initiation of an assessment 

proceeding against Respondent for the recovery of civil penalties for alleged violations of 

section 10(a)(1) of the Shipping Act of 1984, 46 U.S.C. §41102(a); 

WHEREAS, such proceeding would be based on the Commission’s allegations that 

Respondent engaged in certain practices violative of the Shipping Act, to wit: 

Between October 1, 2013, and July 2, 2015, Respondent 

knowingly and willfully allowed third parties to access service 

contract nos. 14-02711 and 12-05034 to which such third 

parties were not contract signatories nor affiliates thereunder, 

and obtain ocean transportation of property from NYK Line, an 

ocean common carrier, at less than the rates or charges that 

would otherwise apply. 

WHEREAS, the Commission is authorized under section 13 (c) of the Shipping Act, 

46 U.S.C. § 41109 (a) – (b), and Subpart W of the Commission’s Rules of Practice and 

Procedure, 46 C.F.R. § 502.601 – 502.605, to compromise and collect civil penalties for 

the alleged violations set forth and described above; 

WHEREAS, Respondent terminated the practices that are the basis of the alleged 

violations set forth herein, and has committed to maintain measures designed to eliminate 

such practices in the future; and 

WHEREAS, Respondent has cooperated in good faith and disclosed to the 

Commission information, facts, and documents relevant to the transportation activities and 

practices giving rise to the allegations stated above; 

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NOW THEREFORE, in consideration of the premises herein, and in compromise of 

all civil penalties arising from the Commission’s investigation of Respondent for the 

alleged violations described above, Respondent and the Commission hereby agree upon 

the following terms of compromise and settlement: 

1. Respondent shall make payment to the Commission by cashier’s or certified check 

or by wire transfer in the total amount of $80,000.00. 

2. This Compromise Agreement shall forever bar the commencement or institution of 

any assessment proceeding or other claim of recovery of civil penalties from 

Respondent, its officers, directors, employees and agents arising from the 

Commission’s investigation of Respondent for the alleged violations set forth above 

that occurred between October 1, 2013 and July 2, 2015. 

3. It is expressly understood that this Compromise Agreement is not, and is not to be 

construed as, an admission by Respondent to the alleged violations set forth above. 

4. This agreement is subject to approval by the Commission’s Managing Director in 

accordance with 46 C.F.R. § 502.604. 

For Respondent: 

British Association of Removers Ltd. d/b/a Movers Trading Club 

Signature: __________________________ 

Printed Name: ______________________ 

Title: ______________________________ 

Date: ______________________________ 

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_______________________________________ 

 

_______________________________________ 

 

APPROVAL AND ACCEPTANCE
 

OF COMPROMISE AGREEMENT
 

The above Terms and Conditions and Amount of Consideration are hereby approved and 

accepted: 

By the Federal Maritime Commission: 

Peter J. King, Director (Date)
 

Bureau of Enforcement
 

Vern Hill (Date)
 

Managing Director
 

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