On October 1, OFAC announced a settlement agreement with The General Electric Company (GE) where GE agreed to pay $2.7 million to settle potential civil liability for 289 alleged violations of the Cuban Assets Control Regulations (CACR). OFAC noted that from 2010 to 2014, three current and former GE subsidiaries accepted payments totaling approximately $8 million from The Cobalt Refinery Company (Cobalt) for goods and services provided to a Canadian customer of GE. Cobalt has been listed on OFAC’s Specially Designated Nationals and Blocked Persons (SDN) List since June 1995 as a specially designated national of Cuba. As such, GE appeared to have violated the CACR by accepting payment from an SDN. OFAC noted that publicly available information also demonstrated that GE’s former Canadian customer is a corporation with strong ties to Cuba. GE voluntarily disclosed the alleged violations, and OFAC determined that the alleged violations constituted a non-egregious case.
For more information on how this could impact your business, contact:
- Martin Lutz, Partner (firstname.lastname@example.org, 512-495-6024)
- Lindsey Roskopf, Attorney (email@example.com, 713-615-8534)
- or another member of the McGinnis Lochridge International Trade and Transactions Practice Group