O'Brien's Response Management, LLC

Shipping
USA
ORM

According to a report filed with the SEC for fiscal year 2013: "Beginning in 2008, O'Brien's Response Management, LLC ("ORM"), an affiliate of SEACOR through its 54.2% economic interest in Witt O'Brien's LLC, was a party to a contract to provide oil spill response services to Libra Shipping S.A. ("Libra"), a shipping company incorporated in the Marshall Islands and registered in Greece. Pursuant to the contract, ORM would assist Libra in coordinating the response in the event of an oil spill. While there has been no oil spill requiring ORM to perform these services under the contract, ORM has provided various other services to Libra, including assisting in developing a response plan for any future oil spills.
On March 14, 2013, Libra was designated as a “Specially Designated National” ("SDN") by the U.S. Treasury Department's Office of Foreign Assets Control ("OFAC") under the Iranian Transactions and Sanctions Regulations, pursuant to Executive Order 13599. Following that designation, ORM has not provided any services or engaged in any transactions under the contract with Libra and no further services are planned. As required by applicable regulations, ORM has submitted a blocked property report to OFAC regarding such contract. In addition, ORM has obtained a specific license from OFAC to terminate the contract with Libra and receive outstanding payments from Libra for services rendered prior to the designation. On April 17, 2013, ORM received the outstanding payments from Libra, which were authorized by OFAC's specific license. As noted, ORM has no further services planned under the contract and has obtained a license from OFAC authorizing ORM to terminate the contract. The services rendered pursuant to the contract prior to Libra's designation as an SDN were not prohibited under any U.S. export controls or sanctions laws and regulations at the time such services were rendered."