Puerto Rico Bank Settles OFAC Charges for Venezuela Sanctions Violations

Banco Popular de Puerto Rico ("BPPR") settled potential civil liability for apparent violations of Venezuela Sanctions Regulations, 31 CFR Part 591.

According to OFAC, BPPR failed to identify and block four personal accounts belonging to two low-level members of the Venezuelan government until October 2020, more than 14 months after the issuance of EO 13884 ("Blocking Property of the Government of Venezuela"). OFAC stated said that BPPR processed transactions in those accounts totaling $853,126. OFAC said BPPR was in possession of documentation that identified the two individuals as members of the Venezuelan government. OFAC highlighted that neither individual met the criteria for an exemption pursuant to Venezuela General License No. 34A ("Authorizing Transactions Involving Certain Government of Venezuela Persons").

OFAC determined that BPPR voluntarily self-disclosed the apparent violations and that the violations constitute a non-egregious case. Further, OFAC recognized as a mitigating factor the various remedial measures taken by BPPR, including (i) voluntarily enhancing its program to better ensure compliance with OFAC sanctions; (ii) reviewing its OFAC policies and procedures for identifying, reviewing and reporting transactions that violate OFAC's regulations; and (iii) enhancing its sanctions screening trainings.

To settle the charges, BPPR has agreed to remit $225,937.86.