OFAC Imposes First Penalty for Russia Sectoral Sanctions Violations
April 29, 2019
On April 25, 2019, Haverly Systems, Inc. (Haverly) agreed to pay a penalty of $75,375 to the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) to settle charges related to two violations of sanctions restrictions for dealings with JSC Rosneft (Rosneft), which is on the U.S. Sectoral Sanctions Identification List (SSI List). While the amount of the penalty is not particularly substantial, the enforcement action is notable as the first one related to SSI List restrictions and because OFAC clearly is sending a message in urging persons to exercise caution when doing business with sanctioned entities (even if the underlying activities are permitted) and to implement effective sanctions compliance programs.
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