Aban Offshore Limited (“Aban Offshore”), of Chennai, India, agreed to pay USD17,500, for violating the US Iran sanctions regime in 2008 with the Office of Foreign Assets Control (“OFAC”). Aban Offshore violated the sanctions, when Aban Offshore’s Singapore subsidiary placed an order for oil rig supplies from a vendor in the US with the intended purpose of re-exporting these supplies from the UAE to a jack-up oil drilling rig located in the South Pars Gas Fields in Iranian territorial waters.
According to OFAC, Aban Offshore did not voluntarily disclose the apparent violation and that the apparent violation constitutes a non-egregious case. OFAC considered the following to be mitigating factors:
1. Aban Offshore has no prior sanctions history with OFAC and has not received a penalty notice or Finding of Violation in the five years preceding the date of this apparent violation;
2. Aban Offshore took remedial action by instituting an OFAC sanctions compliance program; and
3. Aban Offshore displayed substantial cooperation throughout the course of OFAC’s investigation.
The OFAC enforcement notice can be found here.