Sanctions Evasion Reference

Haas: unlock codes for machines owned by blocked Russian entities

A California machine-tool maker paid OFAC $1.04m in 2025 after its Russian distributor sold a CNC machine and parts to eight blocked or majority-owned customers and obtained unlock codes that kept their machines running.

period

2019–2025

outcome

Settlement

parties

Haas Automation, Inc.; Abamet Management Limited

programmes

Russian Federation

reviewed

2026-09-20

Cite this page
APA 7 
Sanctions Evasion Reference. (2026, September 20). Haas: unlock codes for machines owned by blocked Russian entities. https://sanctionsevasion.org/cases/haas-automation-russia-2025/
Chicago 
Sanctions Evasion Reference. “Haas: unlock codes for machines owned by blocked Russian entities.” Last reviewed September 20, 2026. https://sanctionsevasion.org/cases/haas-automation-russia-2025/.
BibTeX 
@misc{ser-cases-haas-automation-russia-2025,
  author = {{Sanctions Evasion Reference}},
  title  = {Haas: unlock codes for machines owned by blocked Russian entities},
  year   = {2026},
  note   = {Last reviewed 2026-09-20},
  url    = {https://sanctionsevasion.org/cases/haas-automation-russia-2025/}
}

The date is when this page was last reviewed, not when it was first published.

Penalties imposed

AuthorityDate AmountNote
OFAC 2025-01-17 $1,044,781 21 apparent violations, 8 of them egregious; not a voluntary self-disclosure. Base penalty $2,985,088.

A case where the goods were exported to a customer that looked ordinary, and the hidden problem was who owned that customer.

What happened

Haas sells machine tools through authorised regional distributors. From 2002 to March 2022 a Russian company, Abamet Management Limited, was its distributor for Russia and Belarus. According to OFAC, between August 2019 and February 2022 Haas indirectly exported through Abamet one CNC machine and 13 spare-parts orders, worth about $98,096, to or for the benefit of six blocked entities. One was itself on the SDN list as a producer of hydroacoustic equipment for the Russian Navy. The other five were owned 50 per cent or more by designated persons, including ones designated for manufacturing armaments and electronic warfare equipment.

The unlock codes

The release adds a detail specific to machine tools. Haas machines sold on instalment plans shut down when a payment is overdue, and a financial unlock code from Haas keeps them running. On seven occasions between December 2019 and March 2022, unlock codes were obtained through Haas for machines owned by five blocked entities, two of them provided by Haas staff directly. OFAC says the codes were “necessary” for the machines to keep operating.

For seven of the eight blocked customers, the release says Haas did not carry out sufficient due diligence on the ownership structure. For the eighth, it did not rescreen the customer against the SDN list before a parts sale.

The penalty

OFAC treated eight of the 21 violations as egregious: the machine and the seven unlock codes. Their base was the statutory maximum for each, $2,945,088, and the 13 non-egregious parts orders came to $40,000, a total of $2,985,088. Haas reported the conduct, but OFAC said its submissions did not count as voluntary self-disclosure. The settlement was $1,044,781. OFAC credited a full internal investigation, a new screening tool that includes customer ownership, training for Haas and distributor staff, an audit procedure for high-risk distributors, and tools to track machine locations.

Haas withdrew from Russia and ended the distributor’s contract in March 2022. The distributor was designated in February 2024.

What the record shows

  • The ownership test was the gap. Of the six blocked entities that received exports, the release describes only one as itself on the SDN list; the other five were caught by ownership. See the 50 percent rule.
  • A product feature became a compliance risk. The unlock code meant a US company kept a continuing relationship with a machine after the sale.

See dual-use re-export.

Techniques this case demonstrates

Programmes and jurisdictions in this case

  • Russia sanctions — Measures imposed from 2014 and greatly expanded from 2022, combining designations, sectoral restrictions, export controls and a price cap on seaborne oil.

Enforcement documents and sources

  1. Enforcement release: Haas Automation, Inc. Settles with OFAC for $1,044,781. U.S. Department of the Treasury, Office of Foreign Assets Control, 2025. Enforcement release, 2025-01-17, US$1,044,781.
  2. Economic Sanctions Enforcement Guidelines, Appendix A to 31 CFR Part 501. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026. Sections I (definitions), II (responses), III (general factors), V.B (penalty calculation).

All enforcement cases