Civil Enforcement Information - Haverly Systems, Inc.

Date issued: Apr. 25 2019

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TURBOFAC Commentary (934 words)

Notes:

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...