APPARENT VIOLATIONS. Between October 2012 and November 2016, Respondent submitted information to OFAC (ENF 40001), the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of Homeland Security, and the Department of Justice (collectively referred to hereafter as the “U.S. government agencies”) that identified transactions and conduct that appear to have violated the Regulations. From on or about January 2010 to on or about March 2016, Respondent engaged in: (i) the exportation, sale, or supply, directly or indirectly, from the United States of goods to Iran or the Government of Iran;
APPARENT VIOLATIONS. 2H Offshore appears to have violated the CACR between 2011 and 2012 when 2H KL performed engineering design analyses for oil well drilling projects in Cuban territorial waters, and sent its engineers to Cuba to conduct workshops in connection with these analyses. 2H KL’s provision of services resulted in the issuance of seven invoices responsive to projects managed by: Petronas Carigali Sdn Bhd (“Petronas”); Repsol S.A. f.k.
a. Repsol YPF S.A. (“Repsol”);
APPARENT VIOLATIONS. On October 24, 2014, Respondent submitted an initial disclosure to OFAC. OFAC opened an investigation into Respondent’s activities (ENF 42933) and requested additional information and documentation from Respondent, including via two administrative subpoenas. OFAC’s review of Respondent’s submissions identified conduct that appears to have violated the Sudanese Sanctions Regulations, 31 C.F.R. part 538 (SSR). Specifically, from on or about June 25, 2014 to on or about October 19, 2015, the Respondent appears to have violated §§ 538.201, 538.205, and 538.206 of the SSR when it exported, through its subsidiary EF Data, satellite equipment under warranty, facilitated ongoing telephone support, and facilitated training despite knowing that the end-user for the equipment and services was Sudan Civil Aviation Authority (SCAA), a Government of Sudan entity located in Sudan (referred to hereafter as the “Apparent Violations”).
APPARENT VIOLATIONS. Keysight submitted a voluntary self-disclosure on behalf of Anite to OFAC. OFAC opened an investigation into activities and requested additional information and documentation from Keysight submissions identified conduct by Anite that appears to have violated the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 ITSR Specifically, from approximately January 2016 to June 2016, Anite appears to have violated § 560.205 of the ITSR when it engaged in six exports of goods intended for Iran with U.S.-origin content controlled pursuant to the Export Administration Regulations, 15 C.F.R. §§ 730-774 EAR valued at $331,089 . The Apparent Violations were voluntarily self-disclosed to OFAC and constitute an egregious case.
APPARENT VIOLATIONS. On December 13, 2011 and June 1, 2012, OFAC issued administrative subpoenas to Respondent, to which it responded on January 12, 2012, July 13, 2012, and August 13, 2012. The administrative subpoena responses identified transactions that appear to have violated the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544 (WMDPSR), issued under the authority of the International Emergency Economic Powers Act, 50 U.S.C. §§ 1701-06 (IEEPA), and other statutes. Specifically, between on or about February 18, 2011 and on or about November 14, 2011, Respondent appears to have violated § 544.201 of the WMDPSR when Respondent dealt in blocked property or interests in blocked property by processing five electronic funds transfers, totaling approximately $472,861, that pertained to payments associated with blocked vessels identified on OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDN List”). These blocked vessels were owned or controlled by, directly or indirectly, the Islamic Republic of Iran Shipping Lines (IRISL), an entity designated by OFAC on September 10, 2008 pursuant to Executive Order 13382 of June 28 2005, “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters” (E.O. 13382).1 The transactions described in the Agreement will be referred to collectively as the “Apparent Violations” hereafter.
APPARENT VIOLATIONS. IARs and employees must report “apparent” or “suspected” violations in addition to actual or known violations. IAR Services and Code of Ethics 20100813
APPARENT VIOLATIONS. On April 28, 2016 and January 6, 2017, Respondent submitted a voluntary self-disclosure to OFAC. OFAC opened an investigation into Respondent’s activities (ENF 45804) and requested additional information and documentation from Respondent. OFAC’s review of Respondent’s submissions identified conduct that appears to have violated the Belarus Sanctions Regulations, 31 C.F.R. part 548 (BSR). Specifically, from on or about January 18, 2012 to on or about October 27, 2015, Zoltek U.S. appears to have violated § 548.201 of the BSR when it dealt in the property or interests in property of J.S.C. Naftan (“Naftan”), a blocked person identified on OFAC’s List of Specially Designated Nationals and Blocked Persons (the “SDN List”), by approving at least 26 transactions between Zoltek ZRT and Naftan (referred to hereafter as the “Apparent Violations”).
APPARENT VIOLATIONS. Between September 2018 and December 2018, Respondent appears to have violated the North Korea Sanctions Regulations, 31 C.F.R. part 510 (NKSR), on at least three occasions. Specifically, Respondent appears to have violated § 510.212 of the NKSR when it caused U.S. persons to export, directly or indirectly, financial services to the Democratic People’s Republic of Korea (DPRK) or otherwise facilitate export transactions that would have been prohibited if engaged in by U.S. persons in apparent violation of §§ 510.206 and 510.211 of the NKSR. These dealings occurred when Respondent received three wire transfers for payments totaling approximately $333,272 (or equivalent value) in their accounts at the foreign branch of a U.S. person financial institution1 for the exportation of cigarette filters to the DPRK (referred to hereafter as the “Apparent Violations”).2
APPARENT VIOLATIONS. On June 25, 2015, Respondent submitted a voluntary self-disclosure to OFAC. OFAC opened an investigation into Respondent’s activities (COMPL 2015-545066) and requested additional information and documentation from Respondent. OFAC’s review of Respondent’s submissions identified conduct that appears to have violated the Cuban Assets Control Regulations, 31 C.F.R. part 515 (CACR). Specifically, from on or about June 26, 2010 to on or about January 15, 2015, GGA processed 2,593 claims reimbursements involving property in which Cuba or a Cuban national had an interest, in apparent violation of § 515.201 of the CACR (referred to hereafter as the “Apparent Violations”). OFAC determined that GGA voluntarily self-disclosed the Apparent Violations and that the Apparent Violations constitute an egregious case.
APPARENT VIOLATIONS. OFAC determined that AL Middle East committed one apparent violation of § 560.203(a) of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (“ITSR”) by causing a U.S. person, Alfa Laval Inc. (“AL U.S.”), to violate § 560.204 of the ITSR by exporting $18,585 worth of U.S.-origin goods indirectly to Iran on or about March 26, 2016. Additionally, AL Middle East committed one apparent violation of § 560.203(b) of the ITSR in forming a conspiracy with two Iran-based firms and one Dubai-based company to cause a U.S. person to violate § 560.204. This conspiracy took place from on or about August 8, 2015 to on or about May 5, 2016 and involved conduct relating to an export worth $18,585 described above, an incomplete export transaction worth $5,170, and future contemplated transactions worth $181,453.1 Enforcement determined that this matter was not voluntarily self-disclosed and determined that the conduct at issue (hereafter the “Apparent Violations”) was egregious.
1 For penalty calculation purposes, only the latter two values are included in the valuation of the transactions that formed the conspiracy under § 560.203(b), as the value of the completed export is included in the penalty associated with the apparent violation of § 560.203(a).
