Note the sanctions violations took place between 2007 and 2009.
In other words, companies that feel protected by the Obama Administration's currently policy do so at their own future risk.
That will change in 65 days.
From U.S. Treasury Department:
National Oilwell Varco, Inc. Settles Potential Civil Liability for Apparent Violations of the Cuban Assets Control Regulations, the Iranian Transactions and Sanctions Regulations, and the Sudanese Sanctions Regulations: National Oilwell Varco, Inc., a Delaware corporation, and its subsidiaries Dreco Energy Services, Ltd. (“Dreco”) and NOV Elmar (“Elmar”) (collectively referred to hereafter as “NOV” unless otherwise noted), have agreed to settle their potential civil liability for apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. part 515 (CACR), the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), and the Sudanese Sanctions Regulations, 31 C.F.R. part 538 (SSR), for $5,976,028.
NOV’s settlement with OFAC is concurrent with both a settlement agreement between NOV and the Department of Commerce’s Bureau of Industry and Security, and a Non-Prosecution Agreement (NPA) executed by NOV with the U.S. Attorney’s Office for the Southern District of Texas.
OFAC determined that from on or about 2002 to on or about 2009, NOV engaged in certain conduct in apparent violation of the ITSR. Specifically: (1) between October 2002 and April 2005, National Oilwell Varco, Inc. approved at least four Dreco commission payments to a U.K.-based entity that related to the sale and exportation of goods, directly or indirectly, from Dreco to Iran, in apparent violation of §§ 560.206 and 560.208 of the ITSR (these four commission payments have a combined value of $2,630,091); (2) between September 2006 and January 2008, National Oilwell Varco, Inc. engaged in two transactions totaling $13,596,980 involving the direct or indirect sale and exportation of goods to Iran, and/or facilitated those transactions, in apparent violation of §§ 560.206 and 560.208 of the ITSR; (3) between at least 2003 and 2007, Dreco knowingly indirectly exported goods from the United States for the specific purpose of filling at least seven orders from Iranian customers, in apparent violation of § 560.204 of the ITSR (these seven transactions have a total value of $526,480); (4) between 2007 and 2009, Dreco engaged in 45 transactions totaling $1,707,964 involving the sale of goods to Cuba, in apparent violation of § 515.201 of the CACR; (5) between 2007 and 2008, Elmar engaged in two transactions totaling $103,119 involving the sale of goods or services to Cuba, in apparent violation of § 515.201 of the CACR; and (6) between 2005 and 2006, NOV engaged in one $20,928 transaction involving the direct or indirect exportation of goods from the United States to Sudan, in apparent violation of § 538.205 of the SSR (collectively referred to hereafter as the “Apparent Violations”).
at 9:32 AM Wednesday, November 16, 2016
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