Yesterday, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its settlement with WATG Holdings, Inc., and its United Kingdom subsidiary, Wimberly Allison Tong and Goo Ltd. (WATG-UK) arising from apparent violations of the Cuban Assets Control Regulations. The parties agreed to settle potential civil liability for a payment of $140,000.

According to the settlement announcement, WATG-UK violated the U.S. embargo against  Cuba by entering into a contact worth approximately $350,000 to provide architectural and design work related to a hotel project in Cuba. WATG-UK received three payments for its services from a Qatari company between October 2009 and May 2010. OFAC indicated that WATG was also directly involved in the dealings with Cuba, as it wrote-off about $70,000 from the original value of the contract.

WATG is a sophisticated multinational architectural firm, that did not have a sanctions compliance program at the time of the apparent violations. These characteristics precisely align with OFAC’s current enforcement prioritization.  In 2015, six of the eight non-financial institutions penalized by OFAC did not have a compliance program. The  enforcement action against WATG and its foreign subsidiary reflects a continuation of targeting non-banks that engage in international commerce without compliance programs commensurate with their risk profiles.

2015 OFAC Penalties