OFAC releases two settlement agreements

January 13, 2017

On January 12, 2017, OFAC announced a $17,500 settlement agreement with Aban Offshore Limited of Chennai, India for its apparent violation of the Iranian Transactions and Sanctions Regulations.  In June 2008, Aban's Singapore subsidiary ordered oil rig supplies from a vendor in the United States with the intended purpose of re-exporting those supplies from the U.A.E. 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 disclose the apparent violation and that the apparent violation constituted a non-egregious case.  In addition, the agency also announced a $10,000 settlement agreement with an individual, acting in his personal capacity, and the Alliance for Responsible Cuba Policy Foundation, on whose behalf the individual also acted, for alleged violations of the Cuban Assets Control Regulations.  On two occasions, the individual engaged in unauthorized travel-related transactions during business travel to Cuba and also provided unauthorized travel services to a total of 20 persons.  OFAC determined that the individual willfully engaged in the alleged violations and did not voluntarily self-disclose the activities to the agency.