OFAC Winter Enforcement Clearance, Day 1

Settlement Agreement between OFAC and Aban Offshore Limited; Settlement Agreement between OFAC and an Individual and the Alliance for Responsible Cuba Policy Foundation

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $17,500 settlement with Aban Offshoe Limited (“Aban”) of Chennai, India.  Aban agreed to settle its potential civil liability for an apparent violation of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560.  The apparent violation occured on the approximate date of June 27, 2008, when Aban’s Singapore subsidiary placed an order for oil rig supplies from a vendor in the United States with the intended purpose of re-exporting these supplies from the United Arab Emirates to a jack-up oil drilling rig located in the South Pars Gas Fields in Iranian territorial waters.  OFAC determined that Aban did not voluntarily self-disclose the apparent violation to OFAC, and that the apparent violation constitutes a non-egregious case.  For more information on this action, please visit the following web notice.

In addition, OFAC separately announced a $10,000 settlement with an individual acting in his personal capacity (the “Individual”), as well as the Alliance for Responsible Cuba Policy Foundation (the “Alliance”), on whose behalf the Individual also acted.  OFAC alleged that the Individual violated § 515.201 of the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (CACR) by engaging in unauthorized travel-related transactions during business travel to Cuba from on or about August 23, 2010 to on or about August 27, 2010, and separately from on or about September 8, 2011 to on or about September 11, 2011; and that the Individual violated § 515.201 of the CACR by providing unauthorized travel services related to the two aforementioned trips to a total of 20 persons.  For more information on this action, please visit the following web notice.

Links:

OFAC Notice

Aban Offshore Enforcement Information

Alliance for Responsible Cuba Policy Foundation Enforcement Information

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