MetLife OFAC Settlement: $22.5K (2011)

In June 2006, MetLife mailed a check representing a $30,162 lump sum death benefit payment directly to the beneficiary in Cuba, in apparent violation of the Cuban Assets Control Regulations, 31 C.F.R. part 515. The matter was not voluntarily disclosed by MetLife; the apparent violation was reported to OFAC and to MetLife by the attorney who administered the estate of the U.S. decedent. Upon receipt of the notice, MetLife stopped payment and deposited the death benefit payment into a blocked account. The funds were subsequently transferred to a bank for distribution to the beneficiary.

The apparent violation constituted a non-egregious case. The base penalty amount was $50,000, the Applicable Schedule Amount established by the OFAC Economic Sanctions Enforcement Guidelines applicable to the apparent violation. MetLife did not voluntarily disclose the matter. OFAC settled for $22,500, reflecting consideration of the following: MetLife provides specialized insurance services; MetLife has not been the subject of prior OFAC penalties; MetLife cooperated with OFAC by making an authorized transfer of the blocked payment to a blocked account opened in the name of the beneficiary for the purpose of making authorized distributions to the beneficiary; and MetLife has taken several steps to strengthen its OFAC compliance program, including requiring sanctions compliance training of all employees.

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