WATG Holdings OFAC Settlement: $140.4K (2016)

The apparent violations of § 515.201 of the Cuban Assets Control Regulations occurred when WATG-UK dealt in property in which Cuba or its nationals had an interest by entering into a contract to perform architectural and design work for a hotel project in Cuba. WATG-UK received three payments from a Qatari company totaling $284,515, from on or about October 13, 2009 to on or about May 20, 2010. WATG further provided the Qatari company a $72,199 write-off of the contract's original value of $356,714.

OFAC determined that WATG did not voluntarily disclose the apparent violations and that the apparent violations constitute a non-egregious case. Both the statutory maximum civil monetary penalty and base penalty amounts totaled $260,000. The settlement amount of $140,400 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: senior managers at WATG-UK performed the primary work related to the project; the apparent violations caused significant harm to the Cuba sanctions program objectives because WATG-UK provided more than $350,000 in architecture and design services in support of Cuba's tourism industry; WATG is a relatively large and sophisticated multinational architectural design company; WATG has no prior sanctions history, including receipt of a penalty notice or Finding of Violation in the five years preceding the earliest date of these transactions; WATG had no OFAC compliance program at the time of the apparent violations; WATG took remedial action by conducting a global, comprehensive compliance review, submitting a disclosure of other transactions to OFAC, appointing a compliance officer, conducting global training of its personnel, and instituting a compliance program to prevent future apparent violations; and WATG agreed to toll the statute of limitations for a total of 877 days.

WATG had no OFAC compliance program at the time of the apparent violations. Following the matter, the company conducted a global, comprehensive compliance review, submitted a disclosure of additional transactions to OFAC, appointed a compliance officer, conducted global training of its personnel, and instituted a compliance program to prevent future apparent violations. These remedial steps were considered in OFAC's settlement determination.

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