Civil Enforcement Information - Vesper Corporation

Date issued: Feb. 02 2007

TURBOFAC Commentary (78 words)

Notes:

1) With respect to the phrase "amended its quotation and order entry procedures to refuse orders from sanctioned countries," query whether and to what extent the mere accepting of an order--while leaving sanctions compliance re: payment processing and shipment for later--constitutes a sanctions violation.

Compare Settlement Agreement - Ericsson, Inc. and Ericsson AB (2018); Civil Enforcement Information - Ericsson, Inc. and Ericsson AB (2018), and comments thereto, suggesting that invoicing without shipping or receiving payment is enough.