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Enforcement Release: July 2, 2025
Key Holding, LLC Settles with OFAC for $608,825 Related to Apparent Violations of Cuban Assets Control Regulations
Key Holding, LLC, a privately held global logistics company based in Delaware, has agreed to pay $608,825 to settle its potential civil liability for apparent violations of OFAC sanctions on Cuba. Between January 2022 and July 2023, Key Holding, LLC’s Colombian subsidiary, then called Key Logistics Colombia S.A.S., managed the logistics for 36 freight shipments from Colombia to Cuba. The settlement amount reflects OFAC’s determination that Key Holding, LLC’s apparent violations were not egregious and were voluntarily self-disclosed, and further reflects the remedial measures implemented upon discovery of the apparent violations.
Description of the Apparent Violations
Key Logistics Colombia S.A.S. (“Key Colombia”), involved in brokering and supplying cargo transportation services, had operated in Colombia since its establishment in 2011. It was acquired...
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1) From a legal basis standpoint, this is a relatively straightforward violation arising out of the CACR's extension of jurisdiction to entities owned or controlled by U.S. persons (515.329). Compare the Cuba portion of Enforcement Release: C.H. Robinson International Inc. (similar factually, including the post-acquisition diligence failure).