Print PDF

Apparent Violation of Cuban Assets Control Regulations Yields $5.2 Million Penalty

Wednesday, July 24, 2013
Sandler, Travis & Rosenberg Trade Report

The Treasury Department’s Office of Foreign Assets Control announced that a travel services company has agreed to pay $5,226,120 to settle a case involving an apparent violation of the Cuban Assets Control Regulations.

The base penalty for the apparent violations was $3,629,250. Aggravating factors include the company’s history of similar apparent violations; the company’s management should have known that the conduct resulting in the apparent violations might take place; the apparent violations caused harm to U.S. sanctions program objectives regarding Cuba; the company is one of the largest and most sophisticated travel services provider for authorized Cuba travel; the company has a significant sanctions history during the five years preceding these apparent violations; the company’s compliance program was inadequate to detect and prevent Cuba travel bookings at the time of the apparent violations; and the company continued to book travel to and from Cuba during a period following disclosure of the apparent violations. On the other hand, the company has not received a penalty notice or Finding of Violation from OFAC in the five years prior to the transactions relating to the apparent violations; and the company provided substantial cooperation with OFAC in producing records and information and engaging in numerous conversations with OFAC.

To get news like this in your inbox daily, subscribe to the Sandler, Travis & Rosenberg Trade Report.

Customs & International Headlines