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.
