For more information, see the web press release and transaction agreement below. The U.S. Treasury`s Office of Foreign Assets Control (OFAC) today announced a comparison with Generali Global Assistance, Inc. (GGA), a New York-based travel support services company. GGA agreed to pay $5,864,860 to settle its potential civil liability for 2,593 clear violations of Cuban asset control rules. GGA deliberately returned the Cuba-related payments to its Canadian subsidiary, thereby avoiding the direct payment of refunds to Cuban parties and travellers while in Cuba. GGA then reimbursed these payments to its Canadian subsidiary. GGA has formally codified this indirect payment process in its procedure manual. OFAC found that the case had been voluntarily brought before OFAC and that the overt violations constituted a monstrous case. In September 2020, OFAC announced its comparison with Comtech Telecommunications Corporation, a New York-based listed company, for violating U.S. sanctions against Sudan. According to OFAC, Comtech`s U.S.

subsidiary, EF Data, sold U.S. equipment to a Canadian company, knowing that the Canadian company would integrate the U.S. equipment into a satellite communications system to be sold in Sudan. (The violations occurred in 2014 and 2015, before the lifting of major U.S. sanctions against Sudan in 2017.) This week, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with Berkshire Hathaway Inc. for clear violations of the U.S. embargo on Iran by a subsidiary in Turkey. As part of the deal, Berkshire Hathaway agreed to pay more than $4.1 million to respond to allegations that the Turkish subsidiary exported 144 deliveries of cutting tools to third-party traders, knowing the goods would eventually be shipped to Iran. Although the infringements were voluntarily referred to OFAC, the Agency found that the Turkish subsidiary`s actions were “monstrous” due to the intentional nature of the subsidiary`s conduct.

Among other things, the leaders of the Turkish subsidiary deliberately did business with Iran when they knew that such transactions were prohibited and took a number of measures to try to conceal their behavior, such as.B the use of third-party intermediaries in Turkey who correspond through personal email accounts and enter false information into internal systems. Finally, the U.S. parent company opened an internal investigation after receiving anonymous information about the subsidiary`s behavior.