SITA AGREES TO PAY $7 MILLION OFAC PENALTY FOR GTSR VIOLATIONS
August 20, 2020
On February 26, 2020, the Office of Foreign Assets Control (OFAC) announced that Société Internationale de Télécommunications Aéronautiques SCRL (SITA) had settled a potential civil liability claim for apparent violations of the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (GTSR). Specifically, SITA was alleged 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 airline customers after OFAC designated those airlines as specially designated global terrorists (SDGTs) pursuant to Executive Order 13224. SITA agreed to pay $7,829,640 to settle its potential civil liability for 9,256 apparent violations which had a statutory maximum civil monetary penalty of $2,453,077,327.
SITA provides commercial telecommunications network and information technology services to the civilian air transportation industry, and membership in the organization is generally open to industry operators worldwide and consists of air transport industry companies and organizations. OFAC initiated an investigation into SITA after discovering that Mahan Air, Syrian Arab Airlines, and Caspian Air — entities previously designated by OFAC as SDGTs — were members of SITA, and that these SDGT airlines may have received or benefitted from SITA’s goods, services, and technology in the form of: (1) Type B messaging (TBM) services; (2) Maestro DCS Local (“Maestro”); and (3) WorldTracer, in violation of U.S. sanctions.
If you have any questions, please contact Evelyn Sahr (esahr@eckertseamans.com or 202-659-6622); Drew Derco (dderco@eckertseamans.com or 202-659-6665), or Andy Orr (aorr@eckertsemans.com or 202-659-6625).
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