Hilton International OFAC Settlement: $735.4K (2010)

OFAC alleged that HI engaged in 142 apparent violations of the Sudanese Sanctions Regulations in connection with its unlicensed operation of two Hilton brand hotels in Sudan between June 2002 and February 2006.

HI voluntarily disclosed this matter to OFAC. Because HI signed a statute of limitation tolling agreement covering alleged violations for which the statute of limitations would have otherwise expired prior to October 16, 2007 (the effective date of the IEEPA Enhancement Act), the settlement is based on the maximum statutory penalties in place at the time the tolling agreement was signed, which equaled $11,000 per alleged violation.

The apparent violations were discovered and self-reported as a result of pre-acquisition due diligence directed by Hilton Hotels Corporation, which acquired HI from the UK-based Hilton Group plc. in February 2006.

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