OFAC Reaches Settlement with Foreign Bank Regarding U.S. Sanctions Violations
Commerzbank AG ("Commerzbank") agreed to pay $1.45 billion to resolve claims that it (i) stripped information from wire transfer requests to hide the connection between the requests and Iranian and Sudanese entities that were subject to U.S. economic sanctions, and (ii) failed to report red flags for potential fraud at Olympus, a Japanese optical company.
In connection with the resolution, Commerzbank agreed to a deferred prosecution agreement that required it to pay a criminal fine of $79 million and to forfeit $563 million. In addition, Commerzbank entered into a deferred prosecution agreement with the New York District Attorney's Office and agreed to pay $171 million (which is credited against Commerzbank's obligation to the United States). The bank also agreed to pay a monetary penalty of $200 million to the U.S. Federal Reserve, and $610 million to the New York Department of Financial Services, as well as a fine of $258.6 million to the Office of Foreign Assets Control, though that fine will be satisfied by payments made to the U.S. Department of Justice.