U.S. bank agrees to pay over $97 million to settle violations of sanctions against Iran, Syria, Sudan

124 apparent violations were voluntarily self-disclosed

124 apparent violations were voluntarily self-disclosed

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) today announced that a U.S. bank agreed to remit $30 million to settle its potential civil liability for apparent violations of sanctions against Iran, Syria, and Sudan. 

According to today’s OFAC release [PDF 228 KB]:

  • For about seven years (2008 – 2015), the bank and its predecessor provided a foreign bank located in Europe with software that the foreign bank then used to process trade finance transactions with U.S.-sanctioned jurisdictions and persons. 
  • The predecessor bank customized a trade insourcing software platform for general use by the European bank that the bank knew or should have known would involve engaging in trade-finance transactions with sanctioned jurisdictions and persons. The European bank then used the platform to manage the transactions.
  • The bank did not identify or stop the European bank’s use of the software platform for trade-finance transactions involving sanctioned jurisdictions and persons for seven years, despite potential concerns raised internally within the bank on multiple occasions.

The settlement amount reflects OFAC’s determination that:

  • The 124 apparent violations were voluntarily self-disclosed.
  • The apparent violations were egregious, but the failure by the bank to identify and prevent the apparent violations was not a result of a systemic compliance breakdown.

The Federal Reserve also issued a release announcing a $67.8 million fine.


For more information, contact a professional with KPMG Trade & Customs services:

Doug Zuvich
Partner and Global Practice Leader
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
E: labad@kpmg.com

Irina Vaysfeld
E: ivaysfeld@kpmg.com

Amie Ahanchian
E: aahanchian@kpmg.com

Christopher Young
E: christopheryoung@kpmg.com

Gisele Belotto
E: gbelotto@kpmg.com

George Zaharatos
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
E: adoornaert@kpmg.com

Jessica Libby
E: jlibby@kpmg.com
John Anderson
Managing Director
E: johneanderson@kpmg.com
Jenna Leigh Glass
Managing Director
E: jennaleighglass@kpmg.com

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