Havana Cuba Business Travel Culture and Politics

Havana Cuba News

Cuba Politics News

Posted November 29, 2011 by publisher in OFAC

Email this article | Print this article | Search Havana Journal        

Commerzbank AG, the second largest bank in Germany, has agreed to pay more than $175,000 to settle violations of the Cuban Assets Control Regulations from 2005. 

The official Civil Penalties Release states that the New York Branch has settled Cuban Assets Control Regulations allegations by remitting $175,500 for apparent violations that occurred in September 2005.

The agreement covers allegations that Commerzbank, acting as an advising and confirming bank in connection with a letter of credit, presented four sets of trade documents, in which a Cuban Specially Designated National (“SDN”) had an interest, to the Miami branch of the foreign bank that issued the letter of credit, for payment in favor of a Canadian company. The aggregate value of the trade documents was $884,157.

Commerzbank did not voluntarily self-disclose the matter, and the alleged violations constituted a non-egregious case.

The base penalty amount for the alleged violations totaled $260,000. The settlement amount reflects OFAC’s consideration of the following facts and circumstances, pursuant to the General Factors under OFAC’s Economic Sanctions Enforcement Guidelines: Commerzbank should have been aware of the prohibited Cuban interest, given that the trade documents contained repeated references to the SDN and its vessels; Commerzbank has undertaken remedial measures to strengthen its OFAC compliance program to ensure that such apparent violations do not recur in the future; and Commerzbank cooperated with OFAC’s investigation, including by agreeing to toll the statute of limitations.

Would you like to add more information?

Only members can add more information. Please register or log in

  • Advertise at Havana Journal Inc
We recommend this AirBnB Food and Drink Experience... Cuban flavors: Food, Rum and Cigars
Images of Cuba
Teddy Roosevelt and the Rough Riders
Follow Havana Journal
SUBSCRIBE to our Cuba Watch newsletter
LIKE us on Facebook

FOLLOW us on Twitter

CONNECT with us on Linked In

Section Archive
Havana Journal, Inc. BBB Business Review

Member of the Association for the Study of the Cuban Economy