Civil Enforcement Information - Yantai Jereh Oilfield Services Group Co., Ltd.

Date issued: Dec. 18 2018

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TURBOFAC Commentary (312 words)

Notes:

1) This enforcement action is relatively straightforward from a legal basis perspective. As is the case here, OFAC often (though not always) separately charges violations of 560.203 (evasion, avoidance) in particularly egregious cases of deceptive practices. The charging of non-U.S. persons under 560.204 for "causing" exportation violations on the part of unwitting U.S. persons is also commonplace (see e.g. Civil Enforcement Information - KMT Group AB, and comments thereto).

This case is somewhat notable insofar as neither OFAC nor BIS charged the U.S. affiliates of the non-U.S. parent with wrongdoing. BIS noted in the settlement agreement that "[the Chinese company] structured the transactions to conceal from the U.S. suppliers of exporters that the [product] ordered was ultimately destined for use in Iran." Compare e.g. Civil Enforcement Information Settlement...