ARTICLE
19 November 2019

Aviation Company Settles OFAC Charges For Potential Violations Of Sudanese Sanctions

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Cadwalader, Wickersham & Taft LLP

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An aviation group settled its potential civil liability with OFAC for apparent violations of the Sudanese Sanctions Regulations.
United States Transport

An aviation group settled its potential civil liability with OFAC for apparent violations of the Sudanese Sanctions Regulations.

According to OFAC, the aviation company may have violated the sanctions regulations by leasing three aircraft engines to an entity based in the United Arab Emirates ("UAE") that in turn subleased the engines to a Ukrainian airline, which then installed the engines onto an aircraft for Sudan Airways. At the time of the transactions, Sudan Air was identified on OFAC's List of Specially Designated Nationals and Blocked Persons.

OFAC stated that while the lease agreement between the aviation company and the UAE-based entity included a provision prohibiting the lessee from involvement with countries subject to sanctions, the aviation company did not obtain certificates of compliance from its counterparty or periodically monitor for compliance during the course of the contract.

To settle the charges, the aviation company agreed to pay $210,600.

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