Acteon Group Ltd.
Acteon’s US investor-parent KKR & Co, violated ISTR on three occasions. Acteon subsidiary, Seatronics, rented or sold equipment to customers that used it on vessels in Iranian territorial waters while KKR-affiliated investment funds owned a majority stake in Acteon. KKR’s majority holdings in Acteon conferred U.S. jurisdiction over Acteon and its subsidiaries’ Iran-related activities and allowed OFAC to penalize Acteon and KKR. Seatronics appears to have violated § 560.215 of the ITSR on three occasions when Seatronics Ltd.’s Abu Dhabi, United Arab Emirates (UAE) branch (“Seatronics-AE”) rented or sold equipment to customers who appear to have embarked the equipment on vessels that operated in Iranian territorial waters.