Background

A California company and its subsidiary in the United Kingdom will pay $140,400 to settle potential liability for apparent violations of the Cuban Assets Control Regulations that occurred when the subsidiary entered into a contract to perform architectural and design work for a hotel project in Cuba.

The statutory maximum civil monetary penalty and base penalty amounts for the apparent violations totaled $260,000. The settlement amount reflects OFAC’s consideration of the following facts and circumstances.

- senior managers performed the primary work related to the project

- the apparent violations caused significant harm to the Cuba sanctions program in light of the value of services provided

- the company is a large and sophisticated multinational company

- the company has no prior sanctions history

- the company did not have an OFAC compliance program at the time of the apparent violations

- the company took remedial action by conducting a global comprehensive compliance review, submitting a disclosure of other transactions to OFAC, appointing a compliance officer, conducting global training of its personnel and instituting a compliance program to prevent future apparent violations

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