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Sanctions This Week: February 22-28, 2016


On February 23rd, 2016, the Office of the Superintendent of Financial Institutions (OSFI) released the United Nations Security Council (UNSC) ISIL (Da’esh) and Al-Qaida Sanctions Committee’s update, underscoring recent information updates on five individuals.

The five individuals are subject to the assets freeze, travel ban and arms embargo set out in paragraph 2 of Security Council resolution 2253 (2015) adopted under Chapter VII of the Charter of the United Nations.  All of the updates relate to their most recent known location, 4 of which being, prison.  The final was a ‘last known address’ update for a Tunisian individual, though he was reported as ‘in detention’ in Tunsia, as at December 2009.

See the update on the United Nations (UN) website.

Go to the OSFI lists page.


The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released two updates last week, but both related to settlement of alleged enforcement actions, or civil penalties related to alleged violations of the Cuban Assets Control Regulations (CACR).  The enforcement actions were on two entities, CGG Services S.A., formerly known as CGGVeritas S.A. (CGG France) and Halliburton Atlantic Limited (HAL) on behalf of itself and its affiliate, Halliburton Overseas Limited (HOL).

See OFAC’s recent actions page.

CGG France has agreed to pay $614,250 USD for numerous alleged violations of Cuban Sanctions, when they exported spare parts and other equipment from the United States to M/V Amadeus while the vessel operated in Cuba’s territorial waters.

See the update on OFAC’s website.

The enforcement actions against HAL were for alleged violations of Cuban Sanctions, by dealing in property in which Cuba, or a Cuban national, had an interest when they exported goods and services in support of oil and gas exploration and drilling activities within the Cabinda Onshore South Block oil concession in Angola. HAL knew, or should have known, they were dealing in property in which Cuba had an interest. HAL issued 19 invoices to the Consortium operator Cupet, a company with headquarters in Angola, related to these goods and services, and HAL primarily performed the services which were invoiced. OFAC determined that the alleged violations were voluntarily self-disclosed and constituted a non-egregious case. The total transaction value of the alleged violations was $1,189,752 USD. The statutory maximum civil monetary penalty for the alleged violations was $1,235,000 USD and the base penalty amount for the alleged violations was $423,202 USD.  HAL has agreed to pay $304,706 USD.

See the update on OFAC’s website.

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