Alliance for Responsible Cuba OFAC Settlement: $10K

Last updated: July 20, 2026

Alliance for Responsible Cuba Policy Foundation and an individual acting in his personal capacity settled potential civil liability for alleged violations of the Cuban Assets Control Regulations, 31 C.F.R. Part 515. OFAC alleged that the individual engaged in unauthorized travel-related transactions during business travel to Cuba and provided unauthorized travel services related to those trips to a total of 20 persons, frequently while holding himself out as an officer of the Alliance. The Alliance agreed to pay $10,000 to resolve the matter.

Penalty Amount

$10,000.00

Enforcement Date

January 12, 2017

Rank in Top Penalties

#548

Case Details

Type:: Entity
Name:: Alliance for Responsible Cuba Policy Foundation
Industry:: Nonprofit
Penalty amount:: $10,000.00
Base civil monetary penalty:: $80,000.00
Max civil monetary penalty:: $1,430,000.00
Egregious case:: Unknown
Voluntary self disclosure:: No
Case:: Settlement
Violation period:: August 23, 2010 to September 11, 2011
Program:: Cuban Assets Control Regulations, 31 C.F.R. Part 515 (CACR)
Enforcement date:: January 12, 2017

Nature of the Apparent Violations

The Individual, acting in his personal capacity and as an officer of the Alliance, violated § 515.201 of the CACR by engaging in unauthorized travel-related transactions during business travel to Cuba from on or about August 23, 2010 to on or about August 27, 2010, and separately from on or about September 8, 2011 to on or about September 11, 2011. The Individual also violated § 515.201 of the CACR by providing unauthorized travel services related to the two aforementioned trips to a total of 20 persons. OFAC concluded that the alleged violations were frequently undertaken while the Individual held himself out as an officer of the Alliance.

How OFAC Determined the Penalty

The alleged violations were not voluntarily self-disclosed to OFAC. The statutory maximum civil monetary penalty amount for the alleged violations was $1,430,000, and the base penalty amount was $80,000. The $10,000 settlement amount reflects OFAC's consideration of aggravating and mitigating factors pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. Part 501, app. A.

Aggravating Factors

The Individual appears to have willfully engaged in the alleged violations involving Cuba with knowledge that such transactions likely constituted violations of the CACR, as evidenced by having been issued a cautionary letter from OFAC prior to the aforementioned trips for similar travel-related transactions to Cuba that appeared to have violated the CACR.
The Individual appears to have knowingly facilitated unauthorized business travel to Cuba by other persons that appears to have violated the CACR.

Mitigating Factors

The alleged violations appear to have resulted in minimal harm to the current objectives of the U.S. sanctions program regarding Cuba.
The investigation involved an individual, acting in his personal capacity, and the Alliance, which is a small nonprofit entity.
Based on the financial condition of the Individual and/or the Alliance, mitigation is warranted.

Official Source Documents

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Archived on June 13, 2026

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