Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Société Internationale de Télécommunications Aéronautiques SCRL

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that Société Internationale de Télécommunications Aéronautiques SCRL (“SITA”), a service provider for the civilian air transportation industry headquartered in Geneva, Switzerland, has agreed to pay $7,829,640 to settle its potential civil liability for 9,256 apparent violations of the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (GTSR) (the “Apparent Violations”).  Specifically, SITA appears to have violated §§ 594.201 and 594.204 of the GTSR between April 2013 and February 2018 when it provided commercial services and software that were subject to U.S. jurisdiction, and benefitted certain SITA member airlines after OFAC designated those airlines as specially designated global terrorists pursuant to Executive Order 13224.  The total transaction value of the Apparent Violations was $2,428,200.  OFAC determined that SITA did not voluntarily self-disclose the Apparent Violations, and that the Apparent Violations constitute a non-egregious case.