American Express Fined $5 Million for Cuba Sanctions Violations

capitolhillcubans

From the U.S. Treasury Department:

American Express Travel Related Services Company, Inc. Settles Potential Civil Liability for Apparent Violations of the Cuban Assets Control Regulations

American Express Travel Related Services Company, Inc. (“TRS”), New York, NY, has agreed to pay $5,226,120 to settle potential civil liability for apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. part 515 (the “CACR”). From on or about December 15, 2005, through on or about November 1, 2011, TRS dealt in property in which Cuba or its nationals had an interest when its foreign branch offices and subsidiaries issued 14,487 tickets for travel between Cuba and countries other than the United States, many of which had adopted “antidote” measures (blocking statutes) prohibiting compliance with the CACR, without authorization from OFAC.

OFAC determined that TRS voluntarily self-disclosed this matter to OFAC and that the apparent violations occurred “subsequent to agency notice” in 1995.

TRS was investigated by OFAC in 1995 and 1996 for similar apparent violations of the CACR arising from the provision of travel services to and from Cuba by a recently acquired subsidiary at the time. OFAC provided written notice to TRS that such conduct constituted apparent violations of the CACR.

Under the Cuba Penalty Schedule, 68 Fed. Reg. 4429 (Jan. 29, 2003), the base penalty for the apparent violations is $3,629,250.