The US Department of Treasury’s Office of Foreign Assets Control has reached a settlement with Société Internationale de Télécommunications Aéronautiques SCRL (SITA), a Switzerland-based commercial telecommunications and information technology organization serving the airline industry. As part of the resolution, SITA agreed to pay $7,829,640 to settle its potential civil liability arising from 9,256 apparent violations of the Global Terrorism Sanctions Regulations (GTSR).
According to OFAC, between 2013 and 2018, SITA violated §§ 594.201 and 594.204 of the GTSR by providing commercial networking and software services to three airlines that were designated by OFAC as global terrorists pursuant to Executive Order 13224. After an OFAC investigation identified the three airlines — Mahan Air, Syrian Aram Airlines, and Caspian Airlines — SITA conducted its own investigation, and confirmed that it was providing services to two additional OFAC-designated airlines, Meraj Air and Al-Naser Airlines. OFAC determined that the services and software provided to these airlines by SITA were subject to US jurisdiction due to the US origin or location of the software and servers.
In determining the settlement amount, OFAC viewed as aggravating factors SITA’s actual knowledge that it was providing services to designated airlines, and SITA’s status as a sophisticated organization operating in dozens of countries. OFAC also took into consideration mitigating factors such as SITA’s cooperation with OFAC’s investigation, the extensive remedial efforts and enhanced compliance undertaken by SITA, its clean record for the five years preceding the apparent violations, and the small volume of the apparent violations relative to SITA’s overall volume of business. In addition, SITA has confirmed that it has terminated the memberships of all designated airlines.