The Office of Foreign Assets Control of the US Department of the Treasury announced on June 13, 2019 that Hotelbeds USA, Inc., a US subsidiary of a Spanish company, has agreed to pay $222,705 to settle potential civil liability for apparent violations of the Cuba Assets Control Regulations, 31 CFR part 515 (CACR). Specifically, OFAC determined that Hotelbeds provided unauthorized Cuba travel related services to 703 individuals between December 2011 and June 2014, and directed payments through Spain. According to OFAC, some US employees of Hotelbeds appear to have had actual knowledge of the conduct that led to the apparent violations, but did not understand that bookings involving non-US clients and payments to non-US accounts could nevertheless violate CACR. In determining the resolution, OFAC considered several aggravating factors, such as Hotelbeds’ failure to voluntarily self-disclose the conduct, and the company’s lack of formal compliance program commensurate with the risks associated with providing international travel services. OFAC also considered mitigating factors, including the minimal volume of Hotelbeds’ overall business represented by the 703 transactions, the company’s remedial action, its clean record for the five years preceding the transactions, and its cooperation with OFAC’s investigation.