Civil Enforcement Information - Alfa Laval Inc.

Date issued: Jul. 19 2021

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TURBOFAC Commentary (324 words)

Notes:

1) Refer to Civil Enforcement Information - Alfa Laval Middle East Ltd., for consolidated commentary on the Alfa Laval Middle East Ltd. portion of the case. BIS issued a single penalty to both Alfa Laval Inc. and Alfa Laval Middle East Ltd. (Settlement Agreement (BIS) - Alfa Laval Middle East Ltd. and Alfa Laval Inc.) OFAC, however, issued separate penalties to the U.S. person and it's UAE affiliate.

As it relates to the referral part of the penalty (560.208), the facts illustrate a textbook example of "referral" as "facilitation," i.e., the facilitation of a transaction by a foreign person that a U.S. person would be prohibited from engaging in directly. The export-related violations, however, are far more notable. Here, OFAC charges a violation of 560.204...