ENFORCEMENT INFORMATION FOR APRIL 11, 2019
Acteon Group Ltd., and 2H Offshore Engineering Ltd. Settle Potential Civil Liability for Apparent Violations of the Cuban Assets Control Regulations: Acteon Group Ltd.
(“Acteon”), an entity organized under the laws of the United Kingdom (UK), and Acteon’s subsidiary 2H Offshore Engineering Ltd. (“2H Offshore”), also organized under the laws of the UK, have agreed to pay $227,500 to settle their potential civil liability for seven apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. part 515 (CACR). The apparent violations occurred when 2H Offshore’s Malaysian affiliates, 2H Offshore Engineering Sdn Bhd and 2H Offshore Engineering (Asia Pacific) Sdn Bhd (collectively referred to hereafter as “2H KL”), produced analytical reports, or sent employees to Cuba to present these reports, for oil exploration projects in Cuban territorial waters between 2011 and 2012 (collectively referred to hereafter as the “Apparent Violations”).[1] 2H...
1) Refer to Settlement Agreement (OFAC) - Acteon Group Ltd., and 2H Offshore Engineering Ltd (2019), which provides some additional factual information.
2) Notes on this enforcement action are separate from the second settlement agreement involving the same company included in the web post. See Civil Enforcement Information - Acteon Group Ltd and KKR & Co. Inc. (Settlement 2 of 2 in web post) (2019).
3) 515.329; "Control" by a Private Equity Firm of a Portfolio Company Not Subject to the CACR On the Basis of Indirect U.S. Person Ownership Alone.
At the time the enforcement action was issued, it was the best available illustration of how there is no limit to the number of corporate layers that OFAC is willing to “see through” in order to assert...