Innospec Inc,entered into a US$2,2 million settlement with OFAC for alleged violations of the Cuban Assets Control Regulations. Innospec’s settlement with OFAC is part of a US$40.2 million comprehensive criminal and civil settlement with the DOJ, Securities and Exchange Commission (SEC), and UK’s Serious Fraud Office (SFO). After acquiring a foreign company that maintained a sales office in Cuba, Innospec allegedly continued to maintain the sales office and engaged in transactions with the Cuba and Cuban nationals. The following factors were taken into account in OFAC’s mitigation of the US$4.4 million base penalty amount for the alleged violations: (i) OFAC first learned of the alleged violations of the Cuba sanctions when Innospec voluntarily disclosed this information to OFAC; (ii) Innospec cooperated not only with the OFAC investigation but also with the investigations by the DOJ, SEC, and SFO; (iii) Innospec sold the foreign subsidiary with operations in Cuba to a non-US third party; and (iv) and Innospec made significant improvements to its trade compliance program.