Halliburton Fined for Cuba Sanctions Violations

Saturday, February 27, 2016
For the second time this week, a reminder that the statute of limitations for sanctions violations does not end with the Obama Administration -- despite The White House's political prodding (and "winks-and-nods") today.

Note these sanctions violations took place in 2011.

From the U.S. Department of Treasury:

Halliburton Atlantic Limited and Halliburton Overseas Limited Settle Potential Civil Liability for Alleged Violations of the Cuban Assets Control Regulations

Halliburton Atlantic Limited (HAL) has agreed to pay $304,706 on behalf of itself and its affiliate, Halliburton Overseas Limited (HOL), to settle potential civil liability for alleged violations of the Cuban Assets Control Regulations, 31 C.F.R. part 515 (the “CACR”), by HAL and HOL.

From on or about February 15, 2011, to on or about April 6, 2011, HAL and HOL, two Cayman Island subsidiaries of the U.S. company Halliburton Energy Services, Inc. (collectively, “Halliburton”), appear to have violated § 515.201(b) of the CACR by dealing in property in which Cuba or a Cuban national had an interest when they exported goods and services in support of oil and gas exploration and drilling activities within the Cabinda Onshore South Block oil concession (the “Concession”) in Angola. Specifically, Cuba Petroleo, a state-owned Cuban company also known as Cupet, held a five percent interest in an oil and gas production consortium (“the Consortium”) and corresponding interests in the Concession and any oil or gas procured within the Concession. HAL and HOL knew or should have known they were dealing in property in which Cupet — and therefore Cuba — had an interest. HAL issued 19 invoices to the Consortium operator, a company with headquarters in Angola, related to these goods and services, and HOL primarily performed the services which were invoiced. The total amount invoiced by HAL was $1,189,752.