A Buenos Aires travel agency that incorporated in Delaware, to evade taxes in Argentina, has now drawn a $2.8m fine from OFAC. It seems that a small portion of the firm's business was selling trips to Cuba. The fact that it was a corporation organized in the US gave OFAC jurisdiction, and it received this large civil penalty for violating sanctions on place against doing business with Cuba.
Though not specifically named in the Treasury notice, it appears that the company received erroneous legal advice, to the effect that it had no liability to OFAC. One wonders if it will now sue its law firm for malpractice.