In your April 30, 2009 posting, When you stated that “EFEX Trade, LLC, a company that provides
both management consulting and massage therapy services, paid $2,000 for unlicensed remittance forwarding to Cuba,” are you saying that EFEX
Trade, LLC is or was an unlicensed remittance?
Or are you saying that EFEX Trade, LLC used an unlicensed remitter to forward payments to Cuba?
I take it to mean they used an unlicensed remitter, but there are some who I shall not name believe
EFEX was the unlicensed remitter.

I am still trying to find information on EFEX Trade, LLC’s sideline business of massage therapy.

Not to be critical of OFAC but have you seen the July 31st, 2009 OFAC’s Release of Civil Penalties? There were only FOUR penalties TOTALLING $41,591 in fines: $10,341; $8,250; $15,000; and $8,000 respectively. It took OFAC over 6 ½ years, from the dates of the effected transactions, to figure out the fines? Can one even imagine the amount of manpower that went into the negotiated fines? Take for example the $8,000 fine for the 2003 violation of the Iraqi Sanctions regulations. How much resources and man hours did OFAC expend in arriving at the $8,000 fine? And since it was not a voluntarily disclosure, how many hours went into the investigation to uncover this? Okay, I am stepping off my soapbox.

Thank you in advance for your assistance and clarification on EFEX Trade, LLC.

Regards,
Kelly Yip