The United States Department of Treasury Office of Foreign Assets Control (“OFAC”) has issued its list of civil penalities imposed during the past month.

This month only one penalty was imposed. That penalty was a civil fine in the amount of $20,958.38 imposed against Lactalis, USA for violations of the Cuban Assets Control Regulations. OFAC alleges that Lactalis made six unlicensed wire transfers in which Cuba or Cuban nationals had an interest.

Only one penalty this month? I don’t know what’s going on at OFAC but they seem to be easing up a little bit. Either that or more effective compliance programs are being implemented. Either way it seems that OFAC has definitely become less strict since our new President took office.

The Cuba Assets Control Regulations can at times be difficult to navigate. If you intend to provide services to entities operating under the jurisdiction of the Government of Cuba, or plan on traveling to Cuba, I strongly suggest seeking out an attorney to advise you on any liability you may face in engaging in such actions.

If you feel that you may have violated the Cuba Assets Control Regulations please contact the author at 202-467-8327 or by email at info@ferrari-legal.com

The author of this blog is Erich C. Ferrari, an attorney in Washington, DC, who specializes in Sanctions Law and White Collar Criminal Defense.