🕵Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and BCC Corporate SA (“BCCC”)
BCC Corporate SA Settles Potential Liability for Apparent Violations of the Cuban Assets Control Regulations: BCC Corporate SA (“BCCC”) is a Belgium-based credit card issuer and corporate service company that issues various payment products, such as credit cards, to its European-based corporate customers.
At the time of the apparent violations, BCCC was a wholly owned subsidiary of Alpha Card which in turn was owned 50 percent by AMEX, a U.S. financial institution.
Between 2009 and 2014, BCCC processed 1,818 transactions totaling $583,649.43 for more than 100 distinct corporate customers of BCCC whose cards were used in Cuba or that otherwise involved Cuba.
The total base penalty amount for the 1,818 apparent violations was $291,825. OFAC has determined that AMEX voluntary self-disclosed the apparent violations to OFAC and that the apparent violations constitute a non-egregious case.
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20171117.aspx