Key Holding, LLC — $608,825 OFAC penalty
OFAC published a $608,825 civil penalty against Key Holding, LLC on 07/02/2025. It is the #124 largest action in OFAC’s 1,052-entry enforcement chart and #14 of the 14 actions published that year.
What OFAC said
FFICE OF FOREIGN ASSETS CONTROL 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.
Quoted verbatim from OFAC’s enforcement release — read the original.
The record
| Entity, as published by OFAC | Key Holding, LLC |
|---|---|
| Penalty / settlement amount | $608,825 |
| Date published by OFAC | 07/02/2025 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #124 of 1,052 |
| Rank within 2025 | #14 of 14 |
| Share of 2025 penalty total | 0.2% |
| Statutory maximum penalty | $4,007,088 |
| Base penalty | $1,217,651 |
| Voluntarily self-disclosed | Yes |
| OFAC egregiousness determination | Non-egregious |
| Sanctions programs named in the release | Cuba |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $4,007,088. The settled amount of $608,825 is 15.2% of that maximum, which OFAC's Enforcement Guidelines tie to factors including voluntary self-disclosure and whether the conduct was egregious.
Primary source
OFAC enforcement release: 20250702_key_holding.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2025 actions
- ShapeShift AG — $750,000
- Haas Automation, Inc. — $1,044,781
- Family International Realty LLC and an Individual — $1,076,923
- An Individual — $1,092,000
- Harman International Industries, Inc. — $1,454,145
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