On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control announced that it reached a settlement with Delaware-based global logistics company Key Holding, LLC (“Key Holding U.S.”) to resolve allegations that it violated U.S. sanctions on Cuba. Key Holding agreed to pay $608,825 to settle its potential civil liability for 36 apparent violations by a Colombian subsidiary that managed logistics for freight shipments to Cuba, according to OFAC. OFAC also indicated that the settlement amount reflected its determination that the apparent violations were voluntarily self-disclosed and were not egregious in nature.
According to the Enforcement Release, Key Holding U.S. acquired a Colombia-based company known at the time as Key Logistics Colombia S.A.S. (“Key Columbia”) in December 2021. According to OFAC, at the time of the acquisition, Key Holding U.S. had no sanctions compliance program that covered non-U.S. subsidiaries, and Key Colombia had no sanctions program in place. Because of this, Key Colombia was reportedly unaware that it was subject to U.S. sanctions and continued to provide logistics services for 36 freight shipments to Cuba, between January 24, 2022 and July 31, 2023, following the acquisition. Of these shipments, 33 allegedly involved foodstuffs that were not eligible for an OFAC license and 3 involved safety-related oil well machinery parts, including components that were shipped using a company that is majority-owned by the Cuban government – transactions that, according to OFAC, violated the Cuban Assets Control Regulations (“CACR”) .
According to OFAC, Key Holding U.S. was unaware that Key Colombia was providing services that supported the shipment of goods to Cuba and was only was able to discover that the subsidiary was providing these services in January 2024, while conducting due diligence in preparation for a pending sale of the company. At that time, Key Holding U.S. also learned that Key Colombia was unaware that it was subject to the CACR. OFAC also emphasized that neither company had sanctions compliance programs in place when the shipments to Cuba occurred. However, as soon as these shipments were discovered, Key Holding U.S. reportedly stopped taking orders for shipments to Cuba and began addressing its compliance deficiencies. On April 1, 2024, Key Holding U.S. allegedly issued its first trade sanctions and export control compliance policy that covered both Key Holding U.S. and its subsidiaries, and implemented a mandatory company-wide sanctions training on April 16, 2024. By July 2, 2024, Key Colombia also began using an automated platform that continuously screened shipments for U.S. sanctions and export control compliance.
OFAC emphasized that this case highlights how important it is for U.S. companies to ensure that newly acquired subsidiaries, including those outside of the United States, are aware of their U.S. obligations, including those under the CACR that extend to foreign subsidiaries owned or controlled by U.S. companies. OFAC also urged U.S. companies to ensure that their subsidiaries adopt and maintain sanctions compliance controls, and ensure that there are systems and protocols in place that enable the careful review of shipping documents and their compliance with U.S. sanctions and export control laws. OFAC also stressed the importance of offering employee trainings and education on the applicability of U.S. sanctions regulations.