The Office of Assets Control of the US Department of the Treasury has announced settlement agreements between OFAC and Acteon Group, Ltd. and its subsidiary 2H Offshore Engineering Ltd., resolving potential civil liability for seven apparent violations of the Cuban Assets Control Regulations, 31 CFR part 515 (CACR). Acteon is an oil and gas service provider based in the UK; its subsidiary 2H Offshore has two Malaysian affiliates, which, according to OFAC, sent engineers to Cuba and conducted engineering design analyses for projects in Cuban territorial waters between May 2011 and October 2012. The company voluntarily disclosed the apparent violations, and will pay $227,500 to settle its potential liability.
In a parallel action, Acteon, KKR & Co. Inc., and three of Acteon’s subsidiaries, Seatronics Ltd, Seatronics, Inc. and Seatronics Ptd. Ltd have agreed to pay $213,866 to resolve potential civil liability for 13 apparent CACR violations and three apparent violations of the Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR). According to OFAC, between August 2010 and March 2012 Seatronics rented or sold oil exploration equipment for use in Cuban waters in violation of § 515.201 of the CACR, and in November 2014, the Abu Dhabi branch of Seatronics Ltd. rented or sold equipment to customers who appear to have delivered the equipment to vessels operating in Iranian territorial waters, in apparent violation of §§ 560.215 and 560.204 of the ITSR. The company also voluntarily disclosed the apparent violations to OFAC.