CWT B.V. OFAC Settlement: $5.99M (2014)

From on or about August 8, 2006, through on or about November 28, 2012, CWT dealt in property in which Cuba or its nationals had an interest when its business units, mostly outside the United States, provided services related to travel to or from Cuba, assisting 44,430 persons. In 2006, CWT became majority-owned by U.S. persons and thus subject to U.S. jurisdiction pursuant to the Trading With the Enemy Act, 50 U.S.C. App. §§ 1-44, and the CACR. CWT processed unauthorized travel-related transactions for more than four years before recognizing that it was subject to U.S. jurisdiction.

OFAC determined that CWT voluntarily self-disclosed the apparent violations. The vast majority of the apparent violations occurred prior to agency notice; a small portion occurred subsequent to agency notice, as they took place after CWT filed its self-disclosure with OFAC. Pursuant to OFAC's Cuba Penalty Schedule, 68 Fed. Reg. 4,429 (Jan. 29, 2003), the base penalty is $11,093,500. The settlement amount of $5,990,490 reflects OFAC's consideration of the following general factors: CWT failed to exercise a minimal degree of caution or care regarding its obligations to comply with OFAC sanctions against Cuba; CWT is a commercially sophisticated international corporation and travel services provider; CWT processed a high volume of transactions and assisted a large number of travelers, causing significant harm to the objectives of the CACR; CWT had no compliance program or an inadequate compliance program at the time of the apparent violations; the transactions were CWT's first violation, as no Finding of Violation or penalty notice had been issued in the five years preceding these transactions; CWT provided substantial cooperation during OFAC's investigation, including agreeing to toll the statute of limitations and providing detailed and well-organized documents and information; and CWT has taken significant remedial action in response to the apparent violations.

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