The Office of Foreign Assets Control (“OFAC”) has fined an individual acting in his personal capacity and Alliance, on whose behalf the individual also acted, for USD10,000 in connection with a violation of the US Cuba sanctions regime.
According to OFAC, the Individual violated the US Cuba sanctions regime by engaging in unauthorized travel-related transactions during business travel to Cuba in August 2010, and September 2011 and that he had provided unauthorised travel services related to the trips in these periods to a total of 20 persons.
OFAC concluded that these violations were frequently undertaken while the individual held himself out as an officer of the Alliance. OFAC also indicated that the violations were not voluntarily self-disclosed to OFAC. OFAC considered the following to be mitigating factors:
1. the Alleged Violations appear to have resulted in minimal harm to the current objectives of the U.S. sanctions program regarding Cuba;
2. the investigation involved an individual, acting in his personal capacity, and the Alliance, which is a small non-profit entity; and
3. based on the financial condition of the Individual and/or the Alliance, mitigation is warranted.
The OFAC enforcement notice can be found here.