OFAC Fines Firm for Cuban Sanctions Violations

The US Treasury Department's Office of Foreign Assets Control ("OFAC") fined a Delaware-based logistics company for violations of US sanctions on Cuba.

According to an OFAC Enforcement Release, a Columbian freight transportation subsidiary of a US based logistics company arranged "for 36 freight shipments" from Colombia to Cuba, totaling more than $3 million in value. OFAC found that 33 of the shipments involved "foodstuffs that were not eligible" for OFAC licensing, while the remaining three involved "safety-related oil well" equipment and consumer goods. OFAC determined that the shipments resulted in "36 apparent violations of the [Cuban Assets Control Regulations]" ("CACR").

OFAC said the US parent company "self-disclosed" the apparent violations when it was preparing to sell the subsidiary. OFAC stated that upon discovering the violations, the parent company ceased handling orders destined for Cuba, "issued its first trade sanctions" compliance policy and implemented "company-wide sanctions training" and automated shipment screening protocols.

To settle the charges, the US company agreed to pay a civil penalty of $608,825. OFAC stated that the calculation of the penalty reflected that the violations were not egregious, were voluntarily self-disclosed and that remedial measures were implemented upon discovery.