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Travel agency settles OFAC CACR violation claim

Philadelphia, PA
10/27/2015
Fine Amount: 
$43,875
Penalty Type: 
Issued by: 

Gil Tours Travel, Inc. (Gil Travel), of Philadelphia, Pennsylvania, has agreed to pay $43,875 to settle potential civil liability for apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. part 515 (CACR). Between October 21, 2009 and August 19, 2010, Gil Tours appears to have violated § 515.201 of the CACR when it dealt in property in which Cuba or Cuban nationals had an interest, by providing Cuba travel-related services involving 191 individuals, without authorization from OFAC.

OFAC determined that Gil Travel did not voluntarily self-disclose the apparent violations and that the apparent violations occurred “prior to agency notice.” Under the Cuba Penalty Schedule, 68 Fed. Reg. 4429 (Jan. 29, 2003), the base penalty amount is $97,500. OFAC reported that the settlement amount was arrived at after considering that Gil Travel

  • had some awareness that it was providing Cuba-related travel services, and that its conduct could be in violation of the CACR;
  • had no sanctions compliance plan at the time of the apparent violations;
  • 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
  • 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.

OFAC announcement: http://www.treasury.gov/resource-center/sanctions/CivPen/Documents/20151...

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