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 |
John L. McLoughlin |
Andy Siciliano |
Steve Brotherton |
Luis (Lou) Abad |
Irina Vaysfeld |
Amie Ahanchian |
Christopher Young |
Gisele Belotto |
George Zaharatos |
Andy Doornaert |
Jessica Libby Principal 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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