- Actions underscore long arm of U.S. sanctions jurisdiction
- Voluntary disclosures and cooperation can lead to significant penalty reductions
- Facilitation of a violation is treated the same as a direct violation
In two recent enforcement actions, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) demonstrated the long-arm of U.S. economic sanctions jurisdiction. One matter involved Société Internationale de Télécommunications Aéronautiques SCRL (SITA), a Swiss firm that provides commercial telecommunications network and information technology services to the civilian air transport industry. The other involved Eagle Shipping International (Eagle), a U.S.-based shipping and logistics company.
Each action serves as a reminder of the U.S. government’s willingness to enforce U.S. sanctions in the context of what is primarily non-U.S. conduct. The resolutions also illustrate the potential benefits of voluntarily disclosing sanctions violations to OFAC.