Treasury Fines Oil Services Company for Cuba Sanctions Violations

Tuesday, February 23, 2016
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 between 2010-2011.

From the U.S. Department of Treasury:

CGG Services S.A., and Its Affiliated Companies, Settle Potential Civil Liability for Alleged Violations of the Cuban Assets Control Regulations 

CGG Services S.A., formerly known as CGGVeritas S.A. (“CGG France”), has agreed to pay $614,250 on its own behalf and on behalf of its affiliated companies, CGG Services (U.S.) Inc., formerly known as CGGVeritas Services (U.S.) Inc. (“CGG U.S.”), and Veritas Geoservices Ltd. S.A. (“Veritas Geoservices”) (collectively the “affiliated companies”), to settle potential civil liability for alleged violations of
the Cuban Assets Control Regulations, 31 C.F.R. part 515 (the “Regulations”). CGG France and its affiliated companies provide services, spare parts, and equipment for oil and gas exploration and seismic surveys.

On or about December 14, 2010, CGG France and CGG U.S. appear to have violated §515.201 of the Regulations when they exported spare parts and other equipment from the United States to M/V Amadeus while the vessel operated in Cuba’s territorial waters.

On or about March 10, 2011, CGG France and CGG U.S. appear to have violated §515.201 of the Regulations when they exported spare parts and other equipment from the United States to M/V Veritas Vantage while the vessel operated in Cuba’s territorial waters.

From on or about February 28, 2011 to on or about July 20, 2011, CGG France appears to have violated §515.201 of the Regulations when, on 13 occasions, it exported U.S.-origin goods from companies unaffiliated with CGG France to the vessel M/V Veritas Vantage while the vessel operated in Cuba’s territorial waters.

From on or about February 1, 2011 to on or about February 3, 2011, CGG France appears to have violated §515.201 of the Regulations when, on two occasions, it exported U.S.-origin goods from companies unaffiliated with CGG France to the vessel M/V Princess while the vessel operated in Cuba’s territorial waters.

From on or about September 20, 2010 to on or about February 22, 2011, Veritas Geoservices, a Venezuelan subsidiary of CGG U.S., appears to have violated §515.201 of the Regulations when it engaged in five transactions at the request of CGGVeritas France involving the processing of data from seismic surveys conducted in Cuba’s Exclusive Economic Zone benefiting a Cuban company.