Treasury Fines U.S. Company for Cuba Sanctions Violations

Sunday, January 31, 2016
Last week, the U.S. Department of Treasury fined a U.S. company for Cuba sanctions violations that took place between 2009 and 2010.

Lesson of the day for U.S. companies: The statute of limitations for Cuba sanctions violations (as codified by the U.S. Congress in law) does not end with the Obama Administration -- nor with a wink-prod-and-nod from current political appointees at the State Department.

From U.S. Department of Treasury:

WATG Holdings, Inc., and Its Subsidiary, Wimberly Allison Tong and Goo (UK) Limited, Settle Potential Civil Liability for Apparent Violations of the Cuban Assets Control Regulations

WATG Holdings, Inc. (WATG), of Irvine, California, and its subsidiary, Wimberly Allison Tong and Goo (UK), Limited (WATG-UK), have agreed to pay $140,400 to settle potential civil liability for apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. part 515 (the “Regulations”). The apparent violations of § 515.201 of the Regulations occurred when WATG-UK dealt in property in which Cuba or its nationals had an interest by entering into a contract to perform architectural and design work for a hotel project in Cuba, for which it received three payments from a Qatari company, from on or about October 13, 2009 to on or about May 20, 2010, totaling $284,515. WATG further provided the Qatari company a $72,199 write-off of the contract’s original value of $356,714.