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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 Construction Specialties Inc. ("CS") on behalf of itself and its subsidiaries and affiliates worldwide, including Construction Specialties, Middle East L.L.C. ("CSME"), (collectively, "Respondent").
I. PARTIES
OF AC 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.
CS, a U.S. person, is a corporation headquartered in Lebanon, New Jersey, engaged in the manufacture and sale of specialized architectural products and construction materials for commercial buildings, such as malls, hospitals, and office buildings. CS has ten offices in the United States...
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1) For consolidated commentary on this settlement agreement and Enforcement Release: Construction Specialties Inc., see commentary on the enforcement release.