Case No. ISA-2014-314312-1
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505 9th Street, N.W., Suite 1000
Washington, DC 20004-2166
Dear Mr. [ ]:
This responds to your request dated November 3, 2014 and additional information dated December 16, 2014, and February 19, 2015 (the “Application”), to the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), on behalf of Twin Fountain Ltd. (“Twin Fountain”), a company incorporated in the British Virgin Islands, requesting authorization or interpretive guidance related to the provision of services by National Oilwell Varco, Inc. (NOV), a U.S. corporation, to the drilling rig vessel UIE 1 (IMO number 9735919). You indicate that Twin Fountain acquired UIE 1 at a judicial auction in the United Arab Emirates. You further indicate that the UIE 1 was constructed in 2013 by Dragon Offshore Industries, LLC. Finally, you state that NOV...
1) Background
In 2008, “Royal Oyster Group acquired Dragon Offshore”. (See https://www.rigzone.com/news/oil_gas/a/70747/thule_sells_newbuilding_rigs_to_uaebased_royal_oyster_group/ and https://x.com/royaloystergrp). In 2011, Royal Oyster Group was blocked pursuant to the Iran Sanctions Act. In 2013, “UIE 1” (an Offshore supply vessel) was built by Dragon Offshore (https://www.balticshipping.com/vessel/imo/9735919). According to the guidance letter, “Twin Fountain [‘a company incorporated in the British Virgin Islands’] acquired UIE 1 at a judicial auction in the United Arab Emirates”. This occurred at some point between the 2013 construction of the vessel and prior to the November 3, 2014, date of the guidance request.
The request to OFAC is a request for “authorization or interpretive guidance related to the provision of services by National Oilwell Varco, Inc. (NOV), a U.S. corporation, to the drilling rig vessel UIE,” where NOV took the position...