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ENFORCEMENT INFORMATION FOR February 7, 2012
Teledyne Technologies, Inc. Settles Sudanese Sanctions Regulations Allegations: Teledyne Technologies Incorporated and its subsidiary, Teledyne RD Instruments, Inc. ("Teledyne"), have agreed to pay $30,385 to settle allegations of violations of the Sudanese Sanctions Regulations, 31 C.F.R. part 538, occurring on or about March 9, 2007 and November 30, 2007. OFAC alleged that on two occasions, Teledyne indirectly exported Acoustic Doppler Current Profilers ("ADCP") to Sudan valued at $122,766. The base penalty amount for the alleged violations was $61,383. OFAC determined that Teledyne voluntarily self-disclosed this matter to OFAC and the alleged violations constitute a non-egregious case. The settlement amount reflects OFAC’s consideration of the following facts and circumstances, pursuant to the General Factors under OFAC’s Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, App. A: Teledyne has no history of prior OFAC violations; the exports of the ADCPs caused minimal harm...
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1) Teledyne provided further details surrounding the facts underlying this violation in a letter to the SEC dated January 3, 2013:
"The transactions underlying the press release to which you refer involve re-exports of certain Acoustic Doppler Current Profilers to Sudan made more than five years ago, in 2007, by a German distributor of Teledyne RD Instruments, Inc., a Teledyne subsidiary. In 2009, when the Company discovered the transactions after a routine internal review, the Company voluntarily self-reported the two shipments to the appropriate agencies, namely the Office of Foreign Assets Control of the U.S. Department of Treasury ("OFAC") and the Office of Export Enforcement of the Bureau of Industry and Security of the U.S. Department of Commerce ("OEE"). After investigation, OEE issued a warning letter in 2010 and, then in or about November 2011, OFAC reviewed the matter and, after recognizing...