CGG Services, a French company providing geological services primarily to the oil and gas industry, has agreed to pay $614,250 to OFAC in settlement of its potential civil liability for apparent violations of US sanctions on Cuba. CGG and its US affiliate CGG Services (US) are said to have breached US sanctions by exporting spare parts and other equipment from the USA to vessels operating in Cuban territorial waters, and by processing data from seismic surveys for the benefit of a Cuban company. CGG is also said to have exported US-origin goods from unaffiliated companies to vessels operating in Cuban territorial waters. The total value of the underlying transactions is said to be $2,758,701, and the base penalty amount for the violations was $975,000, with a maximum of $2,340,000.
In its enforcement notice, OFAC states that CGG’s conduct was aggravated by its reckless disregard for US sanctions in exporting US-origin goods to Cuban waters, particularly after its US affiliate warned it of the sanctions risk in doing so, and performing seismic surveys in Cuban waters without checking for a Cuban interest in the data, and CGG’s knowledge of the conduct. However, OFAC ultimately considered the apparent violations to have been non-egregious, and found CGG’s conduct to have been mitigated by certain attempts it made to comply with sanctions, including removing US personnel and equipment from one of the vessels in question before it entered Cuban territorial waters, adjustment of its supply procedures in view of the apparent violations, and substantial cooperation with OFAC’s investigation.