APPARENT VIOLATIONS. 2H Offshore appears to have violated the CACR between 2011 and 2012 when 2H KL performed engineering design analyses for oil well drilling projects in Cuban territorial waters, and sent its engineers to Cuba to conduct workshops in connection with these analyses. 2H KL’s provision of services resulted in the issuance of seven invoices responsive to projects managed by: Petronas Carigali Sdn Bhd (“Petronas”); Repsol S.A. f.k. a. Repsol YPF S.A. (“Repsol”);
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Sources: Settlement Agreement, Settlement Agreement