Risk Level:
99% May harm your business future; Persons or entities that engage in transactions with this entity will be exposed to sanctions or subject to an enforcement action;

Working with this entity means supporting Iranian Regime, Regime Terrorist Activities & development of WMD

Top Alert – Entity designated / sanctioned for terror, WMD and human rights violation

Morten Innhaug is Chairman at Nordic Maritime Pte. Ltd;

February 7, 2020 Recommended Decision and Order (RDO) – There is sufficient evidence that Nordic Maritime Pte. Ltd. (Nordic) and Morten Innhaug (Innhaug and, collectively, Respondents) violated the Export Administration Regulations (EAR), that Nordic did so knowingly, and that Nordic made false statements to the Bureau of Industry and Security (BIS) in the course of its investigation. Evidence supports the conclusion that Innhaug caused, aided, or abetted Nordic’s unlawful reexport of the survey equipment in violation of EAR. The ALJ recommended a civil monetary penalty of $31,425,760, as well as a denial of export privileges until such time Respondents pay the civil monetary penalty. With respect to the RDO’s monetary penalty recommendation;

Between on or about May 1, 2012, and on or about April 4, 2013, Nordic Maritime engaged in conduct prohibited by the Regulations when it reexported to Iran items subject to the Regulations without the required license. Nordic Maritime reexported the items to the Forouz B natural gas field in Iran without seeking or obtaining authorization from BIS, or from OFAC, in connection with the items. Nordic Maritime used the items to conduct a seismic survey of the Forouz B gas field in furtherance of Mapna Group’s contract with the National Iranian Offshore Oil Company, an Iranian Government entity;

Nordic Maritime transported to and used in Iranian waters U.S.-origin maritime surveying equipment, including specifically compass birds and streamer sections, classified under Export Control Classification Number (“ECCN”) 6A001 and controlled for National Security and Anti-Terrorism reasons (hereinafter, “the items”). The items also were subject to the Iranian Transactions and Sanctions Regulations (“ITSR”), 31 CFR part 560, administered by the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). Nordic Maritime used the items to conduct a seismic survey of Iran’s off-shore Forouz B natural gas field;

The United States has had a long-standing and widely known embargo against Iran. At all times pertinent hereto, Sections 742.4, 742.8, and 746.7 of the Regulations imposed a BIS license requirement for the export or reexport of the items to Iran. In addition, Section 746.7 of the Regulations also prohibited the export or reexport of any item subject to the Regulations if the transaction was prohibited by the ITSR. At all times pertinent hereto, the ITSR prohibited, inter alia, the unauthorized reexportation or supply, either directly or indirectly, of the items to Iran. See 31 CFR 560.204-205. In order to avoid duplication regarding transactions involving items subject to both the Regulations and the ITSR, Section 746.7 of the Regulations provided that authorization did not need to be obtained from both BIS and OFAC, but instead that authorization by OFAC under the ITSR was considered authorization for purposes of the Regulations as well.

Nordic Maritime did not seek or obtain authorization from BIS, or from OFAC, in connection with the items;

Nordic Maritime knew at all times pertinent hereto, including as subsequently admitted in a written submission to BIS dated April 15, 2014, that the items were of U.S.-origin and that it was aware of the U.S. embargo against Iran and related U.S. export controls, including through its own licensing history of BIS license requirements concerning similar items classified under ECCN 6A001 of the Regulations;

In addition, on or about April 11, 2012, Nordic Maritime was warned, via a letter to its Chairman, Morten Innhaug, that its use of the items in Iranian waters would violate U.S. law and would be “in direct breach of the terms of Re-Export License issued by the US Department of Commerce (Bureau of Industry and Security) in relation to use of the Equipment.” (Parenthetical in original). Nordic Maritime received this warning letter from counsel to the company that at the time held a BIS reexport license for the items (hereinafter, “[Reflect Geophysical]”) that had issued in July 2011. Nordic Maritime obtained a copy of the reexport license held by [Reflect Geophysical] no later than on or about June 29, 2012. The license by its terms did not authorize use of the items in Iranian waters or other reexport of the items to Iran by any person or entity, and specifically provided that “no transfer, resale, or re-export of the controlled equipment is authorized without prior [U.S. Government] approval.”;

Notwithstanding the foregoing, Nordic Maritime transported the items to and used them in Iran’s Forouz B natural gas field between on or about May 1, 2012, and on or about at least April 4, 2013, without the required U.S. Government authorization;

As it subsequently admitted in its April 15, 2014 written submission to BIS, Nordic Maritime used the items on a vessel that it had leased from a “Russian State owned company Seismic Geophysical Company” and “that had certain U.S.-origin seismic surveying equipment onboard (streamer sections and compass birds subject to the EAR and classified under ECCN 6A001) that were owned by” [Reflect Geophysical]. (Parenthetical in original). Moreover, Nordic Maritime admittedly conducted the “seismic survey in Iranian waters . . . under a contract that Nordic entered into with Mapna International FZE, a company based in Dubai, UAE.” Furthermore, although feigning ignorance when it contracted to perform the seismic survey in Iranian waters that the survey on behalf of or for the benefit of Iran, Nordic Maritime admitted in its April 15, 2014 submission to BIS that “Mapna International has significant ties to Iran” and that “the work for which Mapna International was contracting was in furtherance of Mapna Group’s contract with the National Iranian Offshore Oil Company to [ ] explore the Forouz B natural gas field.”;

In so transporting and using the items with knowledge that a violation of the Regulations had occurred or was about or intended to occur in connection with them, Nordic Maritime violated Section 764.2(e) of the Regulations;

Shipping Industry

Also Known As:
Morten Inhaug


16 Keppel Bay Drive #04-20 Singapore 098643
Menara Satu Sentra Kelapa Gading Jl. Boulevard Raya LA3 No.1, Lt 08 #0801 Kelapa Gading, Jakarta 14240 Indonesia

+65 6235 0354



Reason for the color:
» In the Matters of: Nordic Maritime Pte. Ltd. and Morten Innhaug Respondents; Partial Remand and Final Denial Order – 03/18/2020;
» The Denied Persons List – Morten Innhaug denied from: 03/11/2020- Expiration Date: 03/08/2035;

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