Civil Enforcement Information - Ameron International Corporation

Date issued: Oct. 24 2013

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TURBOFAC Commentary (606 words)

Notes:

1) Ameron provided more information concerning these violations to the SEC, see https://www.sec.gov/Archives/edgar/containers/fix019/790730/000079073009000020/filename1.htm.

2) Bases for liability:

a) CACR: 515.201(b): On the basis of the facts provided by OFAC, the Cuban component of the enforcement action appears to be a situation similar to Halliburton Atlantic Limited and Halliburton Overseas Limited (2016), in which the provision of goods or services to a company in which Cuba had a minority interest was found to violate the CACR. In that case, the Cuban interest was only 5%, but that 5% was coupled with direct contractual rights to the assets of the consortium, raising the specter of facilitation of that secondary transaction between the consortium and the Cuban company. Here, there is no mention of a separate contract between the Cuban...