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 Settlement Agreements between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Acteon Group, Ltd., 2H Offshore Engineering Ltd., KKR & Co. Inc., and Seatronics Ltd.

 
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $227,500 settlement with Acteon Group Ltd. (“Acteon”), and Acteon’s subsidiary 2H Offshore Engineering Ltd. (“2H Offshore”) that has two Malaysian affiliates: 2H Offshore Engineering Sdn Bhd and 2H Offshore Engineering (Asia Pacific) Sdn Bhd (collectively “2H KL”).  Acteon, a subsea service provider in the oil and gas industry based in the United Kingdom (UK), and 2H Offshore, an engineering contractor based in the UK that specializes in services used in offshore oil and gas drilling production, have agreed to settle their potential civil liability for seven apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. part 515 (CACR).  Specifically, between on or about May 18, 2011 and on or about October 18, 2012, 2H KL performed engineering design analyses for oil well drilling projects in Cuban territorial waters, and sent its engineers to Cuba to conduct workshops on these analyses.  OFAC determined that 2H Offshore voluntarily self-disclosed the apparent violations, and that these apparent violations constitute an egregious case.
 
Separately, OFAC announced a $213,866 settlement with KKR & Co. Inc. (“KKR”), Acteon, and Acteon’s subsidiaries Seatronics Ltd., Seatronics, Inc., and Seatronics Ptd. Ltd. (collectively “Seatronics”).  Acteon has agreed to settle: (1) it and Seatronics’, a geophysical services company based in the UK, potential civil liability for 13 apparent violations of the CACR; and (2) KKR’s, a global investment firm based in New York City, potential civil liability for three apparent violations of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR).  Specifically, between on or about August 12, 2010 and on or about March 16, 2012, Acteon appears to have violated § 515.201 of the CACR when Seatronics rented or sold equipment for oil exploration projects in Cuban territorial waters, and sent company engineers to service equipment on vessels operating in Cuban territorial waters.  In addition, between on or about September 10, 2014 and on or about November 11, 2014, Seatronics appears to have violated §§ 560.215 and § 560.204 of the ITSR when Seatronics Ltd.’s Abu Dhabi, United Arab Emirates branch rented or sold equipment to customers who appear to have embarked the equipment on vessels that operated in Iranian territorial waters.  OFAC determined that Acteon voluntarily self-disclosed the apparent violations, and that these apparent violations constitute a non-egregious case.
 
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Last Updated: 4/11/2019 11:33 AM