Even Obamacare doesn’t cover SDNs: Bupa Florida pays $128,704
OFAC and Bupa Florida agreed to a fine of $128,704 to settle liabilities for 39 apparent violations of the anti-narcotics sanctions programs and Cuba Asset Control Regulations (CACR) between March 2008...
View ArticleOFAC Enforcement Action: ESCO pays $2,057,540 to OFAC for Cuban Sanctions...
ESCO Corporation, an Oregon company, settled allegations that it violated Cuban sanctions regulations between November 2007 and June 2011 when its subsidiary purchased products with nickel of Cuban...
View ArticleDecember 17, 2014: OFAC reacts to Cuba sanctions executive actions
On Wednesday, OFAC issued a single-question addition to their FAQ for the Cuban sanctions program: Q. How will OFAC implement the changes to the Cuba sanctions program announced by the President on...
View ArticleJanuary 15, 2015: New OFAC Cuba sanctions regulations
Sorry for the delay in posting this (work kept me busy, and Mr. Watchlist got a little lazy)… On Friday, January 16th, OFAC posted the amended Cuban Asset Control Regulations (CACR), as well as an FAQ...
View ArticleThe New Math: Multi-agency enforcement actions against Commerzbank AG
Everyone gets a piece of the pie here – the NY Department of Financial Services gets $610 million, OFAC’s official fine is in excess of $250 million (but is deemed paid on the basis of the lesser...
View ArticleMarch 24, 2015: OFAC adds, updates Kingpin Act sanctions, cleans up Cuba...
On March 24th, OFAC added the following to its anti-narcotics trafficking sanctions: KELMENDI, Besnik (a.k.a. KELJMENDI, Besnik); DOB 30 Oct 1980; POB Pec, Kosovo; Passport 5661746 (Bosnia and...
View ArticleMarch 25, 2015: 486 violations net PayPal a $7,658,300 fine
On March 25th, OFAC levied a Civil Monetary Penalty against PayPal for violations of the Iran, Cuba, Sudan, terrorism and Weapons of Mass Destructioin sanctions programs. These violations started in...
View ArticleOFAC’a Cuba Sanctions FAQ – Part I: Embargo
1. Where can I find the amendments to the Cuban Assets Control Regulations (CACR)? Please see the Federal Register. 2. When is the amendment to the CACR effective? The amendment became effective when...
View ArticleOFAC’s Cuba Sanctions FAQ – Part II: Travel
5. What are the travel changes to the Cuba program? OFAC has issued general licenses within the 12 categories of authorized travel for many travel-related transactions to, from, or within Cuba that...
View ArticleOFAC Cuba Sanctions FAQ: Part III – Travel Services
28. Do air carriers need to obtain specific licenses from OFAC to provide services? No. A new general license authorizes persons subject to U.S. jurisdiction to provide air carrierservices to, from,...
View ArticleOFAC Cuba Sanctions FAQ: Part IV – Remittances
31. What changes have been made with respect to authorized remittances by U.S. persons toCuba? The limits on generally licensed periodic remittances that may be sent to a Cuban national, otherthan a...
View ArticleOFAC Cuba Sanctions FAQ: Part V – Banking
Are authorized travelers in Cuba permitted to use credit or debit cards issued by a U.S.financial institution? Yes. Travelers are advised to check with their financial institution before traveling to...
View ArticleOFAC Cuba Sanctions FAQ: Part VI – Trade/Business
44. Is Cuba open for U.S. business and investment? Persons subject to U.S. jurisdiction are prohibited from doing business or investing in Cubaunless licensed by OFAC. An OFAC general license...
View ArticleOFAC Cuba Sanctions FAQ – Part VII – Telecommunications
50. What types of telecommunications and internet-based services are authorized under general license? OFAC has issued an expanded general license which, subject to appropriate conditions, generally...
View ArticleMay 5, 2015: OFAC publishes Cuba Travel Guidance
On Tuesday, OFAC issued a guidance document clarifying the travel restrictions in place with regard to the loosened Cuban sanctions. Question 1: Which individuals may be transported between the United...
View ArticleOFAC Cuba Sanctions FAQ – Part VIII – Third Country Effects
51. Are Cuban nationals located outside of Cuba still considered blocked? Yes, but any individual Cuban national who can establish that he or she has taken up permanent residence outside of Cuba and...
View ArticleOFAC Cuba Sanctions FAQ – Part IX – Miscellany
54. What change has been made to the regulatory interpretation of “cash in advance”? The regulatory interpretation of “cash in advance” has been changed from “cash before shipment” to “cash before...
View ArticleJune 4, 2015: 2 OFAC narcotics changed listings, and lotsa narcotics and Cuba...
On June 4th, OFAC changed the following 2 listings related to narcotics trafficking: CAMACHO VALLEJO, Francisco Jose, Calle 23 BN No. 5-37 of. 202, Cali, Colombia; Carrera 37 No. 6-36, Cali, Colombia;...
View ArticleOFAC Enforcement Action: Navigators Insurance Company fined $271,815
The firm settled 48 apparent violations of sanctions on North Korea, Iran, Sudan and Cuba. The violations were voluntarily self-disclosed and were considered non-egregious. Between 2008 and 2011, the...
View ArticleAugust 27, 2015: More Kingpins, fewer Cubans!
On Thursday, OFAC added the following 4 persons: FONNEGRA ESPEJO, Adolfo, Zurich, Switzerland; Madrid, Spain; DOB 13 Feb 1962; POB Bogota, Colombia; citizen Colombia; Cedula No. 19462357 (Colombia);...
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