Aban Offshore Limited OFAC Settlement: $17.5K (2017)

The apparent violation of § 560.204 of the ITSR occurred on approximately June 27, 2008, when Aban's Singapore subsidiary placed an order for oil rig supplies from a vendor in the United States with the intended purpose of re-exporting these supplies from the United Arab Emirates to a jack-up oil drilling rig located in the South Pars Gas Fields in Iranian territorial waters. The transactional value of the order was $10,127.

OFAC determined that Aban did not voluntarily disclose the apparent violation and that the apparent violation constitutes a non-egregious case. The statutory maximum civil monetary penalty amount for the apparent violation was $250,000, and the base penalty amount was $25,000. The settlement amount of $17,500 reflects OFAC's consideration of the facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. Part 501, app. A.

Aban did not have an OFAC compliance program in place at the time of the transaction despite conducting business with the United States and with U.S. companies in the petrochemical and offshore drilling sectors, which OFAC treated as an aggravating factor. The conduct involved a Singapore subsidiary ordering U.S.-origin goods for re-export through the UAE to a rig located in Iranian territorial waters. Aban's post-discovery remediation was credited as mitigating: Aban instituted an OFAC sanctions compliance program, conducted an internal look-back investigation for potential ITSR violations, and cooperated extensively throughout OFAC's investigation, including by entering into multiple tolling agreements totaling 1,134 days.

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