Late last month, a Philadelphia-based travel company, Gil Tours Travel, Inc. (“Gil Travel”), agreed to pay US $43,875 to OFAC in connection with apparent violations of the CACR. The apparent violations concern the provision of travel services for 191 people traveling to Cuba between October 2009 and August 2010. The services in question involved referring nonprofit agencies to tour operators in Cuba without the requisite OFAC authorization. In determining the penalty, OFAC considered that Gil Travel had awareness that it was providing travel services that could be in violation of the CACR and did not maintain a sanctions compliance program at the time of the violations. The settlement is less than the base penalty amount of US $97,500 in light of the fact that Gil Travel cooperated with OFAC during the investigation and had not received a penalty notice or Finding of Violation in the five years preceding the date of the first transaction.