A Swiss private banking group agreed to pay about $3.7 million to settle allegations that it violated multiple U.S. sanctions programs, including restrictions against Russia and Cuba. The Office of Foreign Assets Control said EFG International AG, which operates about 40 global subsidiaries, bought and sold securities on behalf of people sanctioned by OFAC.
OFAC Sanctions Activity
OFAC administers multiple sanctions programs, including country-specific programs or restrictions against human rights violators, weapons proliferators, narcotics traffickers and more. The agency can impose penalties on people and entities that violate those programs. Here are recent stories about OFAC sanctions activity:
Behrouz Mokhtari of McLean, Virginia, and Tehran pleaded guilty Jan. 9 to two conspiracies to violate U.S. sanctions on Iran "by engaging in business activities on behalf of Iranian entities" without getting a license from the Treasury Department's Office of Foreign Assets Control, DOJ announced Jan. 9. Mokhtari will forfeit money, property and assets obtained from the schemes, including a Campbell, California, home, and a money judgment of over $2.8 million, DOJ said. The defendant faces a maximum of five years in prison for each of the two conspiracy counts.
Export Compliance Daily is providing this recap of export control and sanctions enforcement over the past year to assist export compliance professionals, lawyers and others in keeping pace with current enforcement trends. This guide summarizes the most notable enforcement actions by the Commerce Department's Bureau of Industry and Security, the State Department’s Directorate of Defense Trade Controls, the Treasury Department’s Office of Foreign Assets Control and the Department of Justice since Jan. 1, 2023.
Electronics distribution company Broad Tech System and its president and owner, Tao Jiang of Riverside, California, pleaded guilty Jan. 11 to participating in a conspiracy to illegally ship chemicals made or distributed by a Rhode Island-based company to a Chinese firm with ties to the Chinese military, the U.S. Attorney's Office for the District of Rhode Island announced. Jiang and Broad Tech admitted to violating the Export Control Act and conspiring to commit money laundering.
A New York insurance company reached a $466,000 settlement with the Office of Foreign Assets Control after the U.S. said it provided insurance policies for the blocked company of a sanctioned Russian-Ukrainian oligarch. OFAC said Privilege Underwriters Reciprocal Exchange, which provides insurance policies for luxury homes, cars and boats, continued collecting insurance payments from the company for more than two years after its owner was added to the agency’s Specially Designated Nationals List.
New York-based stock exchange Nasdaq agreed to pay more than $4 million to settle allegations that its former Armenian subsidiary, which owned the Armenian stock exchange, violated U.S. sanctions against Iran. The enforcement notice released by the Office of Foreign Assets Control, which details violations stemming from transactions more than a decade ago, said Nasdaq failed to apply its sanctions compliance policies to the Armenian stock exchange, which illegally allowed the Armenian branch of an Iranian bank to participate.
The Office of Foreign Assets Control’s historic fine of virtual currency exchange Binance could signal more enforcement action against fintech companies, particularly those that may be cutting corners within their sanctions compliance programs, law firms said this month. They also said the case shows OFAC may specifically be targeting companies that don’t have enough compliance buy-in from senior management.
The Office of Foreign Assets Control on Nov. 21 announced a $968 million settlement with Binance, the world’s largest virtual currency exchange, for allegedly violating multiple U.S. sanctions programs when the company allowed people who were either subject to sanctions or located in sanctioned jurisdictions to use its platform. OFAC said Binance senior management knew they were illegally allowing sanctioned users to access its online exchange platform and took steps to “undermine” the company’s own compliance procedures.
An Illinois-based financial services firm reached a $206,213 settlement with the Office of Foreign Assets Control this week after the company allowed its prepaid reward card programs to be used by people in sanctioned regions, including Iran, Syria, Cuba and the Crimea region of Ukraine. OFAC said Swift Prepaid Solutions’ lack of “comprehensive geolocation controls” led to 12,391 violations of U.S. sanctions programs.
Global manufacturing firm 3M reached a $9.6 million settlement with the Office of Foreign Assets Control this week after it allegedly violated U.S. sanctions on Iran. OFAC said the company’s Swiss subsidiary knowingly sold reflective license plate sheeting through a German reseller to Bonyad Taavon Naja, an entity controlled by Iran’s Law Enforcement Forces.