The Treasury Department’s Office of Foreign Assets Control reports that the New York branch of a foreign bank has agreed to remit $28,800 to settle potential civil liability for seven apparent violations of the Global Terrorism Sanctions Regulations. Specifically, this branch processed seven funds transfers that were originated by or destined for the account of a Kyrgyz airline that had been designated by OFAC as an entity committing or supporting terrorism.
The total base penalty amount for the apparent violations was $64,000. The settlement amount reflects OFAC’s consideration of the following as aggravating factors: five of the transactions at issue conferred economic benefit to a sanctioned party, the branch is a sophisticated financial institution and its interdiction filter failed to generate an alert to a blocked entity in seven separate transactions. Mitigating factors include that no branch managers or supervisors were aware of the conduct that led to the apparent violations and that the branch had no OFAC penalties in the previous five years, took appropriate remedial action in response to the apparent violations and cooperated with OFAC’s investigation.
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