Enforcement Release: Haas Automation, Inc. Cobham

Date issued: Jan. 17 2025

Last substantive commentary amendment:
Jan. 24 2025

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TURBOFAC Commentary (430 words)

Notes:

1) From a legal basis perspective, most (14) of the violations included within this enforcement action are similar to Cobham Holdings, Inc. (U.S. person sold goods through a non-U.S. distributor where such goods were destined for a person blocked pursuant to the 50 Percent Rule and the U.S. person had a reason to know that such end user was blocked). These are straightforward indirect export violations. Note that while OFAC points out that the “purchase order is generated” by the Haas Business Center web portal, this type of potential “facilitation” through the passive use of U.S.-based IT infrastructure was not regarded as a violation in and of itself. Hass was actually exporting the parts itself in addition to the other activities.

2) The balance of the violations pertain to the “financial unlock codes”. As a threshold issue, it is...