Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Haverly Systems, Inc.

U.S. Department of the Treasury sent this bulletin at 04/25/2019 10:33 AM EDT

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Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Haverly Systems, Inc.

Haverly Systems, Inc. (“Haverly”), a New Jersey corporation with offices in Texas and California, has agreed to pay $75,375 to settle its potential civil liability for two apparent violations of the Ukraine Related Sanctions Regulations, 31 C.F.R. part 589 (URSR). Specifically, from on or about May 31, 2016 to on or about January 11, 2017, Haverly apparently violated Directive 2 under Executive Order 13662, “Blocking Property of Additional Persons Contributing to the Situation in Ukraine” (“Directive 2”), and § 589.201 of the URSR, when it transacted or otherwise dealt in new debt of greater than 90 days maturity of JSC Rosneft (“Rosneft”), an entity identified by OFAC on the Sectoral Sanctions Identification List as subject to Directive 2.  OFAC determined that Haverly did not voluntary self-disclose the apparent violations to OFAC, and the apparent violations constitute a non-egregious case.

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