Red Bull North America, Inc. OFAC Settlement: $89.8K

Between June 8 and June 18, 2009, seven representatives of RBNA traveled to Cuba to film a documentary, without authorization from OFAC. The production of the film, as well as the associated travel, was approved by RBNA management.

OFAC determined that RBNA did not voluntarily self-disclose the alleged violations and that the alleged violations constituted a non-egregious case. The maximum penalty amount for the alleged violations was $455,000, and the base penalty amount was $105,000. The $89,775 settlement reflects OFAC's consideration of the following facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A: RBNA had prior knowledge of U.S. sanctions on Cuba and took steps to conceal the transactions; RBNA is a U.S. subsidiary of a sophisticated multinational company with extensive experience in international trade; RBNA made a remedial response by instituting an OFAC compliance program; and RBNA has not received a penalty notice or Finding of Violation from OFAC in the five years preceding the date of the unauthorized travel to Cuba.

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