A Saudi bank settled its potential civil liability for apparent violations of Sudan- and Syria-related sanctions.
According to OFAC, in violation of the Sudanese Sanctions Regulations and Section 2(b) of Executive Order 13582, the bank processed 13 U.S. dollar transactions "to or through the U.S. financial system" in circumstances in which:
- a Sudanese or Syrian counterparty benefited; or
- goods were involved "originating in or transiting through" Sudan or Syria.
OFAC concluded that the violations constitute a "non-egregious" case, as the bank voluntarily self-disclosed the eight Syria-related violations, though it did not voluntarily self-disclose the five Sudan-related violations. In determining mitigating factors, OFAC found that the bank enhanced compliance controls in response to past weaknesses, and that most of the Syria-related violations occurred "shortly after" the imposition of the prohibitions. OFAC also noted that none of the Sudanese or Syrian parties who benefited from the transactions were customers of the bank.
To settle charges, the company agreed to pay a $653,347 civil monetary penalty.
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