On June 13, 2019, the Office of Foreign Assets Control of the US Office of the Treasury announced that Expedia Group, Inc., an international travel service provider headquartered in Bellevue, Washington, has settled potential civil liability for apparent violations of the Cuban Assets Control Regulations, 31 CFR part 515. According to OFAC, foreign subsidiaries of Expedia provided travel-related services to 2,221 people who were Cuban nationals or were traveling within, to or from Cuba. OFAC found that Expedia had failed to inform its subsidiaries of US economic sanctions laws, or to inform them that they were subject to US jurisdiction and law.
OFAC determined that Expedia had voluntarily self-disclosed the apparent violations, had cooperated with OFAC’s investigation, had implemented significant remedial measures to strengthen sanctions compliance, and had not received a penalty notice or finding of violation from OFAC in the five preceding years; at the same time, the company had failed to exercise a minimal degree of caution to avoid the conduct, which had occurred over a significant period of time and formed a pattern or practice. In light of the mitigating and aggravating factors, OFAC agreed to the payment of $325,406, which is lower than the base penalty for the apparent violations.