[EXCERPT]
OFAC administers trade and economic sanctions against various countries including, without limitation, Cuba, Iran, Syria, Sudan, and the Crimea Region of Ukraine (“Sanctioned Countries”). As part of our business, we or our agents have arranged for the transportation of personal household effects into or out of Sanctioned Countries on behalf of U.S. and foreign government employees, corporate employees and individuals. These activities have taken place between the United States and Sanctioned Countries and between third countries and Sanctioned Countries. Certain of these activities may have been in violation of OFAC regulations. Although OFAC regulations contain certain general licenses or exceptions that may have been applicable to some of these activities, we filed an initial voluntary self-disclosure with OFAC reporting possible violations with respect to these activities in March 2014, and plan to file our voluntary self-disclosure in October 2015. In between the initial and final voluntary...
* [12-21-22 update - 560.539 has been substantially expanded as of 12-21-22 - comments below do not reflect this]
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1) SIRVA describes itself as follows:
"We are a leading provider of end-to-end relocation and moving services for multi-national corporations, government institutions and consumers, through a worldwide network of 1,475 locations in 170 countries. Our services are designed to provide our customers, typically large corporations, with the ability to efficiently and expeditiously relocate employees globally to execute their business strategies. We provide these services since relocation and moving are outside of our customers’ core competencies. We help manage all aspects of an employee’s relocation and believe that our suite of over 50 distinct services provides an enhanced experience for our corporate and government customers, relocating employees and their families."
As discussed in the excerpted part of the SEC filing, SIRVA was...