Wednesday, November 30, 2011


The Office of of Foreign Assets Control has, very publicly, named & shamed a major German bank for violations of the Cuban Assets Control Regulations. The violation, which appeared in the OFAC Enforcement Information for 29 November, 2011, was given to the bank's New York branch. The statement of facts advises that the bank was the advising and confirming bank for a letter of credit, in connection with trade documents that contained the names of a Cuban Specially Designated National (SDN). 

The Miami branch of an unnamed foreign bank issued the L/C in favour of a Canadian Bank. The amount of the transaction was $ 884,157, and the fine levied by Treasury was $ 175,000 .

When regulators find the name of a sanctioned entity in trade documents, you can be sure that they are looking very carefully at international trade documents for violators of Cuban sanctions. 

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