Rob Sequin | Havana Journal
Office of Foreign Assets Control’s Recent Actions notification service at the U.S. Department of the Treasury has just issued a Release of Civil Penalties Information.
United Nations Federal Credit Union has settled Cuban Assets Control Regulations Allegations
United Nations Federal Credit Union of New York, a federally chartered and regulated credit union, has remitted $500,000 to settle allegations of violations of the Cuban Assets Control Regulations, 31 C.F.R. part 515 (the “CACR”).
OFAC alleged that UNFCU dealt in property in which Cuba or a Cuban national had an interest in violation of the CACR by engaging in certain unauthorized financial transactions on behalf of its members/account holders who were blocked Cuban nationals pursuant to the CACR.
The transactions involved financial services that were routinely provided by UNFCU to its members.
The alleged violations were not voluntarily self-disclosed by UNFCU and were non-egregious in nature.
The base penalty amount for the alleged violations totaled $5,237,100.
The settlement amount reflects OFAC’s consideration of the following General Factors:
UNFCU cooperated with OFAC during the investigation by providing prompt responses to all OFAC inquiries;
UNFCU has undertaken significant remedial measures to augment its OFAC compliance program to ensure OFAC compliance in the future;
a significant portion of the base penalty amount is attributable to many substantially similar apparent violations;
UNFCU has not previously violated OFAC sanctions.
As part of the settlement, UNFCU has further agreed to conduct a review of all of its accounts for compliance with the CACR, and to report the results of that review to OFAC.