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