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Civil Enforcement Information - Ericsson, Inc. and Ericsson AB

Date issued: Jun. 06 2018

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ENFORCEMENT INFORMATION FOR JUNE 6, 2018

Ericsson, Inc. and Ericsson AB Settle Potential Civil Liability for an Apparent Violation of the Sudanese Sanctions Regulations: Ericsson AB ("EAB"), located in Sweden, and Ericsson, Inc. ("EUS"), located in Texas, both of which are subsidiaries of Telefonaktiebolaget LM Ericsson ("Ericsson"), have agreed to pay $145,893 to settle potential civil liability for an apparent violation of the International Emergency Economic Powers Act (IEEPA) and the Sudanese Sanctions Regulations, 31 C.F.R. part 538 (SSR).[1]

OFAC determined that Ericsson voluntarily self-disclosed the apparent violation to OFAC and that the apparent violation constitutes an egregious case. The statutory maximum civil monetary penalty amount for the apparent violation was $360,230, and the base civil monetary penalty amount was $180,115.

On or around September 22, 2011, EAB signed a letter of intent with the Sudanese subsidiary of a third-country telecommunications...

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TURBOFAC Commentary (2049 words)

Notes:

1) Further information provided in Settlement Agreement (OFAC) - Ericsson, Inc. and Ericsson AB.

2) At the time of the violations, the substantive prohibitions of the then-in-effect SSR applied to U.S. persons only. Therefore, neither EAB nor BCom were subject to the SSR, except insofar as they were involved in violations of IEEPA and/or 538.211 of the Sudanese Sanctions Regulations (Evasions; attempts; conspiracies) that did not have an explicitly territorial limitation.

3) While the entirety of the factual scenario set out in the web post and Settlement Agreement could be seen as a single "conspiracy," OFAC breaks out the separate violations, citing to the actual provisions of the SSR violated, in Settlement Agreement. Broadly, OFAC views the technical assistance and the plot to transship the physical item...