OFAC found two United States-based companies (see here and here) in violation of OFAC sanctions reporting Rule 602 ("Reports to be furnished on demand"). OFAC found that the companies provided inaccurate or incomplete information in response to an OFAC investigation.

In its Finding of Violation, OFAC stated that, in May of 2015, it issued an administrative subpoena to DNI Express Shipping Company ("DNI") in connection with a Cautionary Letter sent for possible violations of Sudanese Sanctions Regulations. According to OFAC, DNI used outside counsel to respond to the administrative subpoena. OFAC found that DNI's information was false and misleading. In response, OFAC sent a "follow-up" email to DNI's outside counsel requesting clarification. According to OFAC, the response sent by DNI's outside counsel to the follow-up email was "contradictory, false, materially inaccurate, materially incomplete, and misleading."

In a separate Finding of Violation, OFAC stated that, in June of 2016, it issued an administrative subpoena to Southern Cross Aviation, LLC ("Southern Cross") in connection with the sale of helicopters that were eventually sent to Iran. According to OFAC, Southern Cross failed to respond with complete information.

OFAC reported that both companies ultimately provided the requested information.

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