OFAC has fined US firm National Oilwell Varco (NOV), and its subsidiaries Dreco and Elmar, $5,976,028 in settlement of their civil liability for allegedly violating US sanctions on Iran, Cuba, and Sudan. The settlement is concurrent with a settlement agreement between NOV and the Department of Commerce, and a Non-Prosecution Agreement (NPA) with the US Attorney’s Office for the Southern District of Texas. NOV’s settlement with OFAC will be deemed satisfied by its payment of $25,000,000 under the NPA.
OFAC determined that, between around 2002 and 2009, NOV repeatedly engaged in transactions involving the sale and export of goods to Iran, Cuba, and Sudan. NOV is said to have wilfully blinded itself to Dreco’s deliberate non-identification of Iran in its communications with NOV. It found NOV’s conduct to have been aggravated by, among other factors, the fact that it did not voluntarily disclose the violations, that senior management knew or had reason to know that several of the transactions were benefitting Iran, and that it is a large and sophisticated company involved in regions of high sanctions risk that had a wholly inadequate compliance programme in place. OFAC found NOV’s conduct to have been mitigated by its cooperation with the investigation into its conduct, and its efforts to remediate its compliance programme.
OFAC’s penalty notice is here.