Civil Enforcement Information - Nordgas S.r.l.

Date issued: Mar. 26 2021

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TURBOFAC Commentary (630 words)

Notes:

i) LEGAL BASES FOR THE PENALTY

As it relates to the legal bases for the penalties, the Nordgas case features a familiar set of factual circumstances. When a person not subject to U.S. jurisdiction “causes” a U.S. person to directly or indirectly export goods from the U.S. to Iran, the non-U.S. person violates 560.203 and 560.204 of the ITSR. See General Note on Causing Violations From Abroad (System Ed. Note), and compare Civil Enforcement Information - Yantai Jereh Oilfield Services Group Co., Ltd. In that case, a person not otherwise subject to U.S. jurisdiction “appear[ed] to have violated §§ 560.203 and 560.204 of the ITSR on at least 11 occasions when it exported or reexported, or attempted to export or re-export, U.S.-origin goods ultimately intended for end-users in Iran...