OFAC Charges UAE Bank with Sanctions Violations

OFAC charged a United Arab Emirates Bank ("Bank") for violating now-repealed Sudanese Sanctions by processing monetary transfers from the bank's London branch through U.S. financial institutions.

The Bank processed over 1,760 sanctioned transactions between 2005 and 2009 that were not detected by the Bank's internal supervisory controls in violation of OFAC’s Economic Sanctions Enforcement Guidelines (31 CFR Part 501, App. A). Although OFAC discovered the Bank's violating transactions after the Sudanese Sanctions were removed, OFAC determined that because the Bank voluntarily entered into a "retroactive statute of limitations waiver agreement" OFAC's charges were not time-barred.

OFAC issued a Finding of Violation only and did not issue a civil money penalty due to the Bank's "substantial" cooperative actions including (i) increasing compliance staff, (ii) closing all U.S. accounts of Sudanese banks, (iii) centralizing all due diligence compliance for risk assessment, and (iv) processing only U.S. dollar payments only through U.S. financial institutions as of September 2013.

To settle related charges by the Federal Reserve Board and the New York Department of Financial Services, the Bank agreed to (i) cease and desist from future violations and (ii) implement an enhanced program to ensure global compliance.