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ENFORCEMENT INFORMATION FOR March 27, 2009
Casa de Cambio Delgado, Inc., Settles Allegations of Violations of the Foreign Narcotics Kingpin Sanctions Regulations: Casa de Cambio Delgado, Inc. ("CCDI") of Jackson Heights, NY, has remitted $40,160.46 to settle allegations of violations of the Foreign Narcotics Kingpin Sanctions Regulations. OFAC alleged that on or about January 12 through May 13, 2005, CCDI processed transactions on behalf of Specially Designated Narcotics Traffickers, designated pursuant to the Foreign Narcotics Kingpin Designation Act, without an OFAC license. As a remedial measure, upon learning of the alleged violations, CCDI implemented improvements to its OFAC compliance program in order to prevent future violations. CCDI voluntarily disclosed this matter to OFAC through a blocking report and cooperated with OFAC’s investigation.
The FNKSR make clear that "[t]he [blocking] prohibitions contained in §598.203 apply to services performed by U.S. persons, wherever located: (1) On behalf of or for the benefit of a specially designated narcotics trafficker; or (2) With respect to property interests of a specially designated narcotics trafficker." These facts would apply to both situations.