- Canadian bank pays penalties for U.S. dollar transactions involving Cuba and Iran
- Bank receives Finding of Violation – but no penalty – for violations by European subsidiaries
- Disclosure and cooperation with OFAC mitigated penalties
Earlier this month, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $516,000 settlement with a large Canadian bank for allegedly violating U.S. sanctions against Iran and Cuba 167 times. OFAC also issued a separate finding of 3,491 additional violations by two of the bank’s European subsidiaries – an investment services company and another small bank. Yet OFAC imposed no penalty for the subsidiaries’ alleged violations.
Bass, Berry & Sims’ Government Contracts & International Trade blog features news, commentary and insight on the demanding and ever-changing regulatory environment of contracting with federal, state and local governments, and international trade issues when conducting a global business.