Settlement Agreement (OFAC) - Nordgas S.r.l.

Date issued: Jan. 08 2021

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TURBOFAC Commentary (167 words)

Notes:

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...