Shearman Logo

balance scale

Apr 25, 2014

OFAC Settles Civil Enforcement Action with Dutch Company for Alleged Violations of US Trade Embargo on Cuba

Subscribe

Jump to...

 
The US Treasury’s Office of Foreign Assets Control (OFAC) and Carlson Wagonlit Travel (i.e., CWT B.V.), a Netherlands-based company, have agreed to settle violations of the Cuban Assets Control Regulations (CACRs) dating back to as early as August 2006. Under OFAC’s Cuba Penalty Schedule, the voluntarily disclosed activity exposed CWT to a civil fine of up to $11,093,500. The parties, however, agreed to settle the matter for $5,990,490. This settlement shows that even with the EU Understanding and individual EU member states blocking statutes in place, European companies with US owners can be subject to an OFAC enforcement action.

View full memo, OFAC Settles Civil Enforcement Action with Dutch Company for Alleged Violations of US Trade Embargo on Cuba

Authors and Contributors

Philip Urofsky

Partner

Litigation

+1 202 508 8060

+1 202 508 8060

Washington DC

Danforth Newcomb

Of Counsel

Litigation

+1 212 848 4184

+1 212 848 4184

New York

Stephen Fishbein

Partner

Litigation

+1 212 848 4424

+1 212 848 4424

New York

Paula Howell Anderson

Partner

Litigation

+1 212 848 7727

+1 212 848 7727

New York

Barnabas Reynolds

Partner

Financial Institutions Advisory & Financial Regulatory

+44 20 7655 5528

+44 20 7655 5528

London