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ARTICLE · 11 OCTOBER 2018

Multinational Bank Settles OFAC Sanctions Programs Violations

Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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A multinational bank agreed to pay approximately $5 million to settle a U.S. Department of the Treasury ("Treasury") Office of Foreign Assets Control ("OFAC") investigation to settle charges concerning apparent violations of the Cuban Assets Control Regulations.

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A multinational bank agreed to pay approximately $5 million to settle a U.S. Department of the Treasury ("Treasury") Office of Foreign Assets Control ("OFAC") investigation to settle charges concerning apparent violations of the Cuban Assets Control Regulations, the Iranian Transactions and Sanctions Regulations, and the Weapons of Mass Destruction Proliferators Sanctions Regulations. OFAC stated that JPMorgan Chase Bank, N.A. ("JPMC") self-disclosed the violations. In so doing, OFAC stated that it considered the violations to constitute a "non-egregious" case.

Separately, OFAC issued a Finding of Violation against JPMC for violations of the Foreign Narcotics Kingpin Sanctions Regulations, as well as the Syrian Sanctions Regulations. There is no monetary penalty for a Finding of Violation.

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