OFAC Reports $5.9 Million Penalty for Violation of Sanctions
The Office of Foreign Assets Control [OFAC] reported National Oilwell Varco,Inc., a Delaware corporation, and two subsidiaries have agreed to pay $5.98 million to settle their potential civil liability for apparent violations of the Cuban Assets Control Regulations, the Iranian Transactions and Sanctions Regulations, and the Sudanese Sanctions Regulations.
The conduct engaged in included selling and exporting goods to Iran and/or facilitating those transactions, exporting goods for the specific purpose of filling orders from Iranian customers, engaging in many transactions involving the sale of goods to Cuba, and exporting goods to Sudan.
Contributing factors is the company’s conduct demonstrated at least reckless disregard for U.S. sanctions requirements;
- senior managers knew or had reason to know that their respective business transactions giving rise to the ITSR-related apparent violations involved Iran
- the company’s conduct provided a significant and sustained economic benefit to the petroleum industries in Cuba, Iran, and Sudan
- the company’s compliance program at the time of the apparent violations was wholly inadequate
Some Mitigating factors –
- the company had not received a penalty notice or finding of violation in the previous five years
- cooperated with OFAC’s investigation, including by agreeing to toll the statute of limitations for more than 2,600 days
- has made efforts to remediate its compliance program and agreed to further compliance enhancements
To read the entire enforcement information-> OFAC
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