On February 22, 2016, CGG Services S.A. (CGG), an oil and gas exploration company based in France, agreed to pay $614,250 to OFAC to settle alleged violations of the Cuban Assets Control Regulations (CACR). According to OFAC, in 2010 and 2011, CGG and its U.S. affiliate exported items subject to U.S. export controls, such as spare parts and equipment used for oil and gas exploration, to Cuba's territorial waters on multiple occasions. In 2011, the Venezuelan subsidiary of CGG's U.S. affiliate processed data from seismic surveys conducted in Cuba's economic zone, which ultimately benefited a Cuban company. OFAC concluded that CGG did not voluntarily disclose the alleged violations.

In determining the settlement amount, OFAC considered the following as aggravating factors: (1) CGG acted with reckless disregard for U.S. sanctions by exporting U.S.-origin goods after being informed that such exports were in violation of U.S. sanctions; (2) CGG's affiliate did not determine whether processing data for seismic surveys benefitted a Cubanentity; (3) CGG was aware that U.S.-origin items were being transported aboard vessels to Cuba; and (4) the transactions significantly undermined U.S. sanctions objectives due to the nature of the items. OFAC also took into account the following mitigating factors in reducing the penalty for the alleged violations from the base penalty of $975,000: (1) CGG did not have a sanctions penalty or Finding of Violation in the past five years; (2) CGG took steps to avoid sanctions violations by removing U.S. personnel and items from vessels operating in Cuban territorial waters; (3) CGG adjusted its supply procedures to avoid future sanctions violations; and (4) CGG and its affiliates cooperated with OFAC's investigation.

For more information, see OFAC's  notice of enforcement.

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