OFAC - $1.7 Million Penalty Against Bank for Processing Transactions for Sanctioned Entity

OFAC – $1.7 Million Penalty Against Bank for Processing Transactions for Sanctioned Entity

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $1,700,100 settlement with UBS AG (UBS) - financial institution headquartered in Switzerland. UBS agreed to settle its potential civil liability for 222 apparent violations of the Global Terrorism Sanctions Regulations. OFAC states that this enforcement action highlights the importance of institutions, including foreign financial institutions that purchase, sell, transfer or otherwise transact in U.S. securities, taking appropriate measures to ensure compliance with all applicable sanctions when they have operations or otherwise conduct business in multiple jurisdictions that have implemented sanctions against particular individuals, entities or countries.

The total base penalty amount for the apparent violations was $3,778,000 that included several aggravating factors.. The following were considered mitigating factors: the bank had not received a penalty notice or finding of violation from OFAC in the previous five years, has a global sanctions policy in place that requires it to comply with the sanctions programs administered by OFAC, took remedial action in response to the apparent violations (including a thorough internal investigation), and substantially cooperated with OFAC’s investigation.

NOTE: Although the bank identified all of the apparent violations, OFAC advises that these did not constitute voluntary self-disclosures because they were substantially similar to another apparent violation of which OFAC was already aware.

To read all the details: OFAC Enforcement

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