OFAC Enforcement - Halliburton Atlantic Limited and Halliburton Overseas Limited

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (886 words)

Notes:

1) BASES FOR LIABILITY:

OFAC recounted that Halliburton:

"deal[t] in property in which Cuba or a Cuban national had an interest when they exported goods and services in support of oil and gas exploration and drilling activities [to an oil concession] in Angola...[A] state-owned Cuban company...held a five percent interest in an oil and gas production consortium [ ], and corresponding interests in the Concession and any oil or gas procured within the Concession."

One law firm client alert [1] discussing this enforcement action presumed/speculated that the key to this enforcement action was the provision in the (515.302) that considers non-Cuban companies to be Cuban "nationals" if a "substantial part" of the "stocks...or other obligations" of the company are owned by a Cuban, and that while the 5% interest was not necessarily enough to...

Welcome!

Welcome!

Civil Enforcement Information - Halliburton Atlantic Limited and Halliburton Overseas Limited

TURBOFAC Commentary (886 words)