October 27, 2015: Gil Tours Settles for $43,875 OFAC Fine

Between October 2009 and August 2010, Gil Tours violated the Cuban Asset Control Regulations by providing travel-related services for 191 persons. The base penalty for these non-voluntarily self-disclosed violations that occured “prior to agency notice” was $97,500.

Here is OFAC's math as to how the fine got reduced to $43,875:

• Gil Travel had some awareness that it was providing Cuba-related travel
  services, and that its conduct could be in violation of the CACR;
• Gil Travel had no sanctions
  compliance plan at the time of the apparent violations;
• Gil Travel 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
• Gil Travel substantially cooperated with
  OFAC during its investigation of the apparent violations, including by entering into a statute of
  limitations tolling agreement for a total of 446 days.

Link:

OFAC Enforcement Information

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