PRINT
ENFORCEMENT INFORMATION FOR APRIL 25, 2019
Haverly Systems, Inc. Settles Potential Civil Liability for Apparent Violations of the Ukraine Related Sanctions Regulations. Haverly Systems, Inc. (“Haverly”), a New Jersey corporation with offices in Texas and California, has agreed to pay $75,375 to settle its potential civil liability for two apparent violations of the Ukraine Related Sanctions Regulations, 31 C.F.R. part 589 (URSR). Specifically, from on or about May 31, 2016 to on or about January 11, 2017, Haverly appears to have violated Directive 2 under Executive Order 13662, “Blocking Property of Additional Persons Contributing to the Situation in Ukraine” (“Directive 2”), and § 589.201 of the URSR, when it transacted or otherwise dealt in new debt of greater than 90 days maturity of JSC Rosneft (“Rosneft”), an entity identified by OFAC on the Sectoral Sanctions Identification List (the “SSI List”) as subject to Directive 2. OFAC added...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
1) This is the first penalty based on a violation of any SSI Directive (compare Civil Enforcement Information - S&P Global, Inc., a 2022 penalty also based on Directive 2).
2) OFAC's references to violations of "Directive 2 under Executive Order 13662...and...§ 589.201 of the URSR" are presumably not a way to describe separate violations. Instead. 589.201 merely says that all transactions prohibited under certain EOs are violations of 589.201. EO 13662 is one of those EOs, and Directive 2 is, in turn, issued under the authority of EO 13662. Any single violation of an SSI directive inherently implicates all three authorities.
This however lends itself to the question of how OFAC figured there were "two apparent violations of the Ukraine Related Sanctions Regulations."
The actual...