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A Dallas-based global payments company settled potential civil liability with OFAC for alleged violations of multiple sanctions regulations.
According to OFAC, in connection with services the company provided to the DOJ's Federal Bureau of Prisons, the company:
- failed to screen customers against the List of Specially Designated Nationals and Blocked Persons ("SDN List");
- processed transactions for blocked individuals as a result of human error and "screening, technology and fuzzy logic failures"; and
- inappropriately determined that commercial transactions related to Syria qualified as noncommercial, personal remittances.
OFAC determined that the company violated the Foreign Narcotics Kingpin Sanctions Regulations (Rule 598.203, "Prohibited Transactions involving Blocked Property"), the Narcotics Trafficking Sanctions Regulations (Rule 536.201, "Prohibited Transactions involving Blocked Property"), the Syrian Sanctions Regulations (Rule 542.207, "Prohibited Exportation, Reexportation, Sale, or Supply of Services to Syria"), the Democratic Republic of the Congo Sanctions Regulations (Rule 547.201, "Prohibited Transactions involving Blocked Property"), the Central African Republic Sanctions Regulations (Rule 553.201, "Prohibited Transactions") and the Weapons of Mass Destruction Proliferators Sanctions Regulations (Rule 544.201, "Prohibited Transactions involving Blocked Property"). OFAC determined that the violations were voluntarily self-disclosed and did not constitute an egregious case.
To settle the charges, the company agreed to pay a $34,328 civil money penalty. The company also agreed to continue the implementation of "strong remedial action," including improved screening, training and investments in compliance-related functions.
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