United Nations FCU OFAC Settlement: $500K (2010)

OFAC alleged that UNFCU dealt in property in which Cuba or a Cuban national had an interest in violation of the CACR by engaging in certain unauthorized financial transactions on behalf of its members/accountholders who were blocked Cuban nationals pursuant to the CACR. The transactions involved financial services that were routinely provided by UNFCU to its members.

The alleged violations were not voluntarily self-disclosed by UNFCU and were non-egregious in nature. The base penalty amount totaled $5,237,100. The $500,000 settlement amount reflects OFAC's consideration of the following General Factors: UNFCU cooperated with OFAC during the investigation by providing prompt responses to all OFAC inquiries; UNFCU has undertaken significant remedial measures to augment its OFAC compliance program to ensure OFAC compliance in the future; a significant portion of the base penalty amount is attributable to many substantially similar apparent violations; and UNFCU has not previously violated OFAC sanctions. As part of the settlement, UNFCU also agreed to conduct a review of all of its accounts for compliance with the CACR and to report the results of that review to OFAC.

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