RE #4
That's the way I heard it too.
Supposedly it was World Pay, which is a UK based CC processor, and not Ravi who actually gave the transaction info to the government.
From what I heard, the letters were kind of interesting, since all OFAC had was a record of payment, but no shipment manifests, they weren't actually "that letter" but rather something along the lines of "We noticed you spent money at a vendor who sells Cuban cigars, if you bought Cuban cigars from him, tell us how many you bought."
Since at the time Ravi also sold Phillipine cigars, humidors, accessories and possibly other non-Cuban merchandise, they really couldn't prove anything.
From what I understand, the option to use World Pay is no longer available on his site.