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 Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Apollo Aviation Group, LLC

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $210,600 settlement with Apollo Aviation Group, LLC (“Apollo,” now d/b/a Carlyle Aviation Partners Ltd.).  Apollo, a U.S. company organized and headquartered in Florida, has agreed to settle its potential civil liability for 12 apparent violations of the Sudanese Sanctions Regulations, 31 C.F.R. part 538.  Specifically, Apollo appears to have violated §§ 538.201 and 538.205 when it leased three aircraft engines to an entity incorporated in the United Arab Emirates, which then subleased the engines to a Ukrainian airline, which then installed the engines on an aircraft wet leased to Sudan Airways (“Sudan Air”).  At the time of the transactions, Sudan Air was identified on OFAC’s List of Specially Designated Nationals and Blocked Persons as meeting the definition of “Government of Sudan."

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Last Updated: 11/7/2019 1:19 PM