Willbros USA OFAC Settlement: $6.6K (2009)

OFAC alleged that Willbros, through a former Senior Vice President, willfully violated the Sudanese Sanctions Regulations (the "Regulations") when it entered into a contract to bid on an oil development project in Sudan, despite its knowledge that such activities violated the Regulations, by facilitating the export of goods, technology or services to Sudan and evading the prohibitions set forth in the Regulations. The apparent violations occurred between June 18, 2003 and December 29, 2004.

Willbros voluntarily disclosed this matter to OFAC. OFAC applied its 2003 Economic Sanctions Enforcement Guidelines to this violation because Willbros and OFAC agreed to settle the allegation of violation, and memorialized the tentative agreement, prior to the issuance of OFAC's Civil Penalties Interim Policy of November 27, 2007. The matter was resolved according to the prior enforcement guidelines published by OFAC at 68 Fed. Reg. 4422, resulting in a settlement of $6,600.

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