ESG Enforcement Tracker

In late 2021, the DOJ and USAO for the Southern District of Florida notified Sunseeker International Limited (Sunseeker International), registered in the UK, and Sunseeker USA Sales Co. Inc (Sunseeker USA), registered in the state of Florida (collectively Sunseeker), that they were investigating the companies for potential violations of the Lacey Act related to the illegal import of Myanmar teak.

The investigation related to allegations that, between April 2021 and February 2023, the companies had procured from the EU and knowingly sold and shipped into the US, yachts that contained, and parts of yachts that were made of, teak harvested in Myanmar valued at approximately US$20,400 as well as a US$650 teak door. This was done in violation of the UK Timber and Timber Products (Placing on the Market) Regulations 2013, as amended (SU 2013/233) (the UKTR), the purpose of which is to prevent timber that was illegally harvested from being placed on the market.

On 11 April 2023, Sunseeker International was charged in the UK with three counts of violating the UKTR. On 14 June 2023, it pleaded guilty to all three counts and was sentenced on 25 November 2024 to a fine of GBP358,760.60. The UK Crown Court had found that the “company failed at a systemic level to address the obvious environmental and social risks that accompany the continued presence of unregulated rare hard woods in its supply chain”. The teak imported into the US came from the illegal imports that were charged in the UK case.

On 11 May 2026, both companies pleaded guilty in the US to two violations of the Lacey Act and agreed to pay a fine of US$200,000 and to implement a compliance plan. The sentencing date is scheduled for 20 August 2026.