Nordic Maritime Pte. Ltd.

On March 11, 2020, Nordic Maritime Pte. Ltd. (Nordic), and its Chairman, Morten Innhaug (Innhaug), were found to have committed four violations of the EAR for their respective roles in the illegal reexport of controlled undersea surveying equipment to Iran for use in surveying an Iranian oil field. Specifically, between May 2012 and April 2013, Nordic knowingly used seismic surveying equipment classified under ECCN 6A001, and controlled for National Security and Anti-Terrorism purposes, to conduct a survey of the Forouz B natural gas field in Iranian territorial waters under a contract for the ultimate benefit of the state-owned National Iranian Offshore Oil Company. Nordic and Innhaug were informed by the owner of the items that their use in Iranian waters would violate the EAR and was provided with a copy of the BIS re-export license issued to the owner listing all of the license conditions, but they nevertheless proceeded to re-export the items to Iran without authorization from either BIS or the Department of Treasury’s Office of Foreign Assets Control. Upon discovery of the violations by BIS, Nordic then made a written submission falsely stating that the owner of the items had never advised Nordic that the equipment was subject to a BIS re-export license, never provided Nordic with a copy of the re-export license, and never advised Nordic of the license conditions.