OFAC Enforcement Action: WATG Holdings & subsidiary run afoul of Cuban sanctions

The firm provided architectural design services for a Cuban hotel between 2009 and 2010, for which it was paid $284,515. The settlement? Roughly half – $140,000, for a non self-disclosed, non-egregious case. The base penalty, which was the statutory maximum, was $265,000.

Here is what OFAC considered in making its decision:

Senior managers at WATG-UK performed the primary work related to
the project;

The apparent violations caused significant harm to the Cuba sanctions program
objectives because WATG-UK provided more than $350,000 in architecture and design services
in support of Cuba’s tourism industry;

WATG is a relatively large and sophisticated
multinational architectural design company;

WATG has no prior sanctions history, including
receipt of a penalty notice or Finding of Violation in the five years preceding the earliest date of
these transactions;

WATG had no OFAC compliance program at the time of the apparent
violations;

WATG 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; and

WATG agreed to toll the statute of limitations for a total of 877
days.