U.S. companies agree to settle violations of Ukrainian and Sudanese sanctions

Two Texas-based companies have agreed to settle their potential civil liabilities for apparent violations of Ukrainian and Sudanese sanctions.

Ukrainian and Sudanese sanctions

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) today announced that two companies located in Texas have agreed to settle their potential civil liabilities for apparent violations of Ukrainian and Sudanese sanctions.

  • According to one OFAC release [PDF 211 KB], a Houston, Texas-based supplier of goods and services for the oil and gas industries has agreed to pay approximately $1.4 million to settle its potential civil liability for apparent violations of the Ukraine-related sanctions regulations. Specifically, between July 2015 and November 2016, U.S. individuals who were senior managers at the company approved contracts for its Romanian subsidiary to supply goods to a Russian energy firm (subject to the restrictions of the U.S. executive order). The Romanian subsidiary’s requests to the U.S. company for approval of the contracts variously referenced the provision of oil production or exploration goods to the Russian energy firm’s offshore project and indicated that the Russian arctic was the destination of the oil-related goods. OFAC determined that the U.S. company did not voluntarily self-disclose the apparent violations and that the apparent violations constitute a non-egregious case.
  • A second OFAC release [PDF 196 KB] explains that a U.S. company based in Frisco, Texas, has agreed to pay $160,000 to settle its potential civil liability for an apparent violation of OFAC’s now-repealed Sudanese sanctions regulations. Specifically, between December 2015 to April 2016, three U.S. individuals (employees of the company) facilitated the sale and shipment of oilfield equipment from a Canadian subsidiary to a Chinese joint venture of the company for onward delivery to Sudan. The facilitation by the company’s employees of a transaction to deliver oilfield equipment to Sudan was, at the time of the transaction, an apparent violation. OFAC determined that the company’s conduct was non-egregious and was not voluntarily self-disclosed.


For more information on this topic or to learn more about KPMG’s Trade & Customs Services, contact:

Doug Zuvich
Partner and Global Practice Leader
T: 312-665-1022
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
T: 267-256-2614
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
T: 631-425-6057
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
T: 415-963-7861
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
T: 212-954-3094
E: labad@kpmg.com

Irina Vaysfeld
T: 212-872-2973
E: ivaysfeld@kpmg.com

Amie Ahanchian
T: 202-533-3247
E: aahanchian@kpmg.com

Christopher Young
T: 312-665-3229
E: christopheryoung@kpmg.com

Gisele Belotto
Managing Director
T: 305-913-2779
E: gbelotto@kpmg.com

George Zaharatos
T: 404-222-3292
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
T: 313-230-3080
E: adoornaert@kpmg.com

Jessica Libby
Managing Director
T: 612-305-5533
E: jlibby@kpmg.com


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