How I stopped Cuba from making money off Google

Did you know the federal government has a list of individuals, companies, and web sites that you are not allowed to transact with financially? If you didn't, you may want to review the Office of Foreign Assets Control. Their web site is found here:

http://www.treas.gov/offices/enforcement/ofac/

How Cuba Was Making Money off Google
I was surfing through the Office of Foreign Assets Control and saw that they had a number of web sites listed that should not be involved in any financial transaction with any US individual or firm.

Through the list, I found that http://www.realestatecuba.com/ was using Google's AdSense network. They were showing off Google's advertisements in return for some financial benefit. Here's how it works (roughly): Let's say Google gets 10 cents if someone clicked on an advertisement, Cuba would get 1 cent for displaying it on their www.realestatecuba.com web site.

There's no problem in making money this way, except for the fact that Google isn't allowed to financially transact with Cuba or any other sanctioned government (ie: like North Korea or Iran).

I sent off an e-mail to Google
I like Google because they are not evil (except their stock price). So I sent them a kind email telling them they might be breaking a few laws. Here's my email on January 8th:


From: "Don Sausa"
Subject: Google AdSense possibly violating federal sanctions
Date: Sun, 8 Jan 2006 04:36:57 -0500

Dear Google,

Please escalate to management or legal team for advise. On your AdSense program, you currently have http://www.realestatecuba.com/ listed. This web site is blacklisted in the Treasury Department's Office of Foreign Assets Control (OFAC) and any transaction with this web site and its owners could be in violation of U.S. trade sanctions against Cuba.

OFAC's publications regarding violation of sanctions state that:

"Economic sanctions are used by the U.S. government to prevent targeted countries, entities, and individuals from, among other things, accessing the U.S. financial system for purposes that are contrary to U.S. foreign policy and national security objectives."

...

"Depending on the program involved, criminal violations of the statutes administered by OFAC can result in penalties ranging from $50,000 to $10,000,000 and/or up to 30 years imprisonment for willful violations. OFAC also has authority to impose civil penalties of up to $1,075,000 per violation depending on the sanctions program."

I highly suggest that your web site managers compare the list of "Specially Designated Nationals (SDN) List" to make sure that you are legally compliant with U.S. trade sanctions. The most recent list of individuals can be found here:

http://www.treas.gov/offices/enforcement/ofac/sdn/sdnlist.txt

If you have any questions about US trade law or the persons listed in this list, please forward these questions over to OFAC. If you ever need help in doing compliance audits with your company, let us know.

Thanks,

Don Sausa
Team Asylum Compliance Team
http://www.team-asylum.com
"Security requires manual vigilence."


Google responds within 48 hours
What I like about Google is that when they find something that's broke, they fix things. I received a response from them on January 11th, 2006 (see email below). As of January 13th, 2006, the web site http://www.realestatecuba.com/ is no longer displaying advertisements for Google's AdSense. YEY! Castro's no longer making money off Google on this web site.


-----Original Message-----
From: Google AdSense Policy Enforcement [mailto:adsense-support@google.com]
Sent: Wednesday, January 11, 2006 8:30 PM
To: Don Sausa
Subject: Re: [#43211366] Google AdSense possibly violating federal sanctions


Hello Don,

Thank you for reporting this to us. We will investigate this matter and take necessary actions, as appropriate.

Sincerely,

The Google AdSense Team


If anyone else is bored out there, feel free to do what I did. Fight against terrorists or Communists by simply...surfing the Internet. :-)

-dohboy