CGG Services OFAC Settlement: $614.2K (2016)

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 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 on 13 occasions when 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 on two occasions when 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 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.

OFAC determined that CGG France did not voluntarily self-disclose the alleged violations and that the alleged violations constitute a non-egregious case. The statutory maximum civil monetary penalty amount was $2,340,000 and the base penalty amount was $975,000. The settlement amount of $614,250 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.

CGG France acted with reckless disregard for U.S. sanctions requirements by exporting U.S.-origin goods to Cuban waters, especially after its U.S. affiliate informed it that such exports could be a violation of U.S. sanctions. Veritas Geoservices similarly acted with reckless disregard by performing data processing related to seismic surveys conducted in Cuban waters without determining if there was a Cuban interest in the data. CGG France was aware of the conduct giving rise to the alleged violations because it knew where the vessels were located and the origin of the goods; the underlying transactions had a total value of $2,758,701 and were related to oil exploration.

CGG France took some steps to avoid OFAC violations as part of its compliance program, including removing U.S. personnel and equipment for M/V Vantage prior to it entering Cuba's territorial waters, and subsequently adjusted its supply procedures to minimize the risk of future sanctions violations. CGGVeritas agreed to toll the statute of limitations and substantially cooperated with Enforcement's investigation.

This page summarizes an OFAC enforcement case based on the document archived below. SanctionsLookup assumes no liability for errors, omissions, or inaccuracies in the original documents, this summary, or any changes made to the source documents at any time.

Provided for informational purposes only and does not constitute legal or compliance advice. Always consult the source document directly rather than relying on this summary.