Enforcement Release - Cameron International Corporation

Date issued: Sep. 27 2021

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TURBOFAC Commentary (1382 words)

Notes:

1) BASIS FOR LIABILITY: SEEMINGLY PRECEDENTIAL STATEMENTS CONCERNING TRADITIONAL “FACILITATION” AS AN INDIRECT PROVISION OF “SERVICES” TO A SANCTIONS TARGET/“IN SUPPORT OF” A PROHIBITED DIRECTIVE 4 PROJECT

SSI Directive 4, as it existed as of the time of the alleged violations, provided in relevant part as follows, with emphasis added:

“…the following activities by a U.S. person or within the United States are prohibited…: the provision, exportation, or reexportation, directly or indirectly, of goods, services…or technology in support of exploration or production for deepwater, Arctic offshore, or shale projects that have the potential to produce oil in the Russian Federation, or in maritime area claimed by the Russian Federation and extending from its territory, and that involve any person determined to be subject to this Directive