OFAC Enforcement - Innospec, Inc.

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 (1627 words)

Notes:

1) Company under broader federal investigation received voluntary disclosure credit for specific activities not yet known by OFAC.

2) Foreign subsidiary subject to the via §515.329 (Person subject to the jurisdiction of the United States; person subject to U.S. jurisdiction).

3) This is a rare case in which, unlike successor liability cases in which an acquirer is liable for activities of a target undertaken prior to the acquisition, the activities of the acquired target continued after the acquisition were the basis for liability.

4) For more information refer to Civil Enforcement Information - Innospec, Inc..

5) Innospec provided more information about the violations in correspondence with the SEC:

*Bycosin disposal

Voluntary disclosure of possible violations of the Cuban Assets...

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Civil Enforcement Information - Innospec, Inc.

TURBOFAC Commentary (1627 words)