OFAC Settles With Expedia for Cuban Sanctions Violations

The Treasury’s Office of Foreign Assets Control announced a $325,000 settlement with Expedia Group Inc. for helping more than 2,000 people with “Cuba-related travel services” that OFAC said violated the Cuban Assets Control Regulations, according to a June 13 enforcement notice.

Between 2011 and 2014, OFAC said, Expedia helped about 2,221 people, some Cuban nationals, with travel services within Cuba or between Cuba and locations outside the U.S. OFAC said the violations occurred because certain Expedia foreign subsidiaries “lacked an understanding of and familiarity with U.S. economic sanctions,” and said employees “overlooked particular aspects of Expedia’s business that presented risks of noncompliance with sanctions.”

OFAC said some “electronically booked travel” resulted from “failures or gaps … in technical implementations” to avoid violations. Expedia did not inform a subsidiary that it was subject to U.S. sanctions compliance until about 15 months after it was acquired, the notice said. OFAC also said Expedia was “slow to integrate the subsidiary into the Expedia corporate family,” specifically with compliance policies, and said the subsidiary “continued operating independently during the integration period.”

Expedia self-disclosed the violations, the notice said. OFAC said aggravating factors included Expedia’s failure “to exercise a minimal degree of caution or care” to avoid the violations,” the fact that the violations “harmed the sanctions program objectives of the CACR,” and that Expedia is a “sophisticated international travel service provider.” OFAC said mitigating factors included the fact that Expedia had not received a penalty in the previous five years, had implemented “significant remedial measures” and cooperated with OFAC’s investigation. Expedia agreed to “enhance” compliance procedures through several conditions, including installing a compliance management team and conducting “regular risk assessments.”