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Clifford Chance

Clifford Chance


Chemistry Lesson: OFAC Reacts to Post-Acquisition Cuba Business in Latest Settlement

15 February 2019

On February 14, 2019, OFAC announced a settlement with Germany-based AppliChem GmbH for 304 violations of the Cuban Assets Control Regulations (31 C.F.R. part 515). This is OFAC's third settlement of 2019, and largest financial penalty imposed this year ($5,512,564). Once again, OFAC reminds companies of the cost of inadequate post-acquisition due diligence and internal controls.

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