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The Treasury Department’s Office of Foreign Assets Control announced Oct. 27 that a Pennsylvania company has agreed to pay $43,875 to settle potential civil liability for providing Cuba travel-related services involving 191 individuals without OFAC authorization in apparent violation of the Cuban Assets Control Regulations. OFAC determined that the company did not voluntarily self-disclose the apparent violations, which occurred “prior to agency notice.”
The base penalty amount for the apparent violations is $97,500. On the one hand, OFAC states, the company had some awareness that it was providing Cuba-related travel services and that its conduct could be in violation of the CACR and had no sanctions compliance plan at the time 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 preceding the date of the first transaction giving rise to the apparent violations and substantially cooperated with OFAC during its investigation.