ARTICLE
11 October 2018

Multinational Bank Settles OFAC Sanctions Programs Violations

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
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.
United States International Law

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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