The Long Arm of U.S. Sanctions: Penalty Imposed Against Canadian Subsidiary of U.S. Subsidiary of Japanese Company

On June 8, the Office of Foreign Assets Control (OFAC) announced a monetary penalty against American Honda Finance Corporation (American Honda) for alleged violations of the Cuban Assets Control Regulations (CACR), the primary regulations by which the United States imposes economic sanctions on Cuba.  A copy of the OFAC press release announcing the penalty is available here.The penalty amount, approximately $88,000, is not particularly noteworthy.  Nor, as was the case with certain other OFAC matters, did the enforcement action take particularly long to conclude: the conduct occurred between 2011 and 2014.