OFAC Civil Penalties Release
Metropolitan Life Insurance Company Settles Cuban Assets Control Regulations Allegations
Metropolitan Life Insurance Company, New York, NY (“MetLife”) has remitted $22,500 to settle allegations of a violation of the Cuban Assets Control Regulations, 31 C.F.R. part 515, which were promulgated pursuant to the Trading With The Enemy Act, 50 U.S.C.
OFAC alleged that, in June 2006, MetLife mailed a check representing a $30,162 lump sum death benefit payment directly to the beneficiary in Cuba. This matter was not voluntarily disclosed by MetLife. The alleged violation was reported to OFAC and to MetLife by the attorney who administered the estate of the U.S. decedent.
Upon the receipt of the notice, MetLife stopped payment and deposited the death benefit payment into a blocked account. The funds were subsequently transferred to a bank for distribution to the beneficiary. The alleged violations constituted a non-egregious case.
The base penalty amount for MetLife’s apparent violation was $50,000, the Applicable Schedule Amount established by the OFAC Economic Sanctions Enforcement Guidelines applicable to the apparent violation.
The settlement amount reflects OFAC’s consideration of the following:
1. MetLife provides specialized insurance services
2. MetLife has not been the subject of prior OFAC penalties
3. MetLife cooperated with OFAC by making an authorized transfer of the blocked payment to a blocked account opened in the name of the beneficiary for the purpose of making authorized distributions to the beneficiary
4. MetLife has taken several steps to strengthen its OFAC compliance program, including requiring sanctions compliance training of all employees.
Please visit the Havana Journal’s sister site CubaLegalServices.com for a summary page of OFAC information.