Recently, OFAC settled with a Portland, Oregon based manufacturer for allegedly violating the Cuban Assets Control Regulations, 31 C.F.R. part 515. The manufacturer agreed to pay $2,057,540 for the actions of its subsidiary, which “purchased nickel briquettes made or derived from Cuban-origin nickel between on or about November 7, 2007, and on or about June 11, 2011.” OFAC concluded that the manufacturer self-disclosed the supposed violations and such violations “constitute a non-egregious case.” Under the Economic Sanctions Enforcement Guidelines, OFAC noted that the manufacturer “acted with reckless disregard for Cuba sanctions program,” and caused “significant harm to…its policy objectives by conducting large-volume and high-value transactions in products made or derived from Cuban-nickel.”