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ENFORCEMENT INFORMATION FOR DECEMBER 12, 2018
Yantai Jereh Oilfield Services Group Co., Ltd. Settles Potential Civil Liability for Apparent Violations of the Iranian Transactions and Sanctions Regulations: Yantai Jereh Oilfield Services Group Co., Ltd., headquartered in Yantai, China, and its affiliated companies and subsidiaries worldwide (collectively referred to hereafter as the "Jereh Group"), have agreed to pay $2,774,972 to settle the company’s potential civil liability for 11 apparent violations of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR).
The Jereh Group’s settlement with OFAC is concurrent with a settlement agreement between the Jereh Group and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS).
Specifically, from on or about October 2, 2014 to on or about March 4, 2016, the Jereh Group appears to have violated §§ 560.203 and 560.204 of the ITSR on at least...
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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...