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SETTLEMENT AGREEMENT
This settlement agreement (the “Agreement”) is made by and between the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) and Nordgas S.r.l. and its subsidiaries and affiliates (collectively referred to hereafter as “Nordgas” or “Respondent”).
I. PARTIES
OFAC administers and enforces economic sanctions against targeted foreign countries, regimes, terrorists, international narcotics traffickers, and proliferators of weapons of mass destruction, among others. OFAC acts under Presidential national emergency authorities, as well as authority granted by specific legislation, to impose controls on transactions and freeze assets under U.S. jurisdiction.
Respondent, an Italian entity located in Costa Masnaga, Italy, develops and designs electronic boards and components for gas boiler applications and sells air pressure switches for gas boiler systems.
II. APPARENT VIOLATIONS
Between March 23, 2013 and March 31, 2017, Nordgas appears to have violated §§...
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1) Refer to Civil Enforcement Information - Nordgas S.r.l. for consolidated comment on the Nordgas case.
2) In general, a settlement agreement that ends up on OFAC’s website is one in which the posting of the “entire agreement” is specifically contemplated in the settlement agreement itself, and the settlement agreement is normally signed in close proximity to the posting of the agreement on OFAC’s website. Here, the settlement agreement does not account for the possibility of OFAC posting the actual agreement on the website, the settlement agreement was signed months prior to the enforcement release being announced, and the enforcement release announcement did not make mention of the posting of the settlement agreement (suggesting that the settlement agreement was posted on some date following the posting of the enforcement release). This is highly unusual -- it is possible that...