A French bank that facilitates trade finance settled potential civil liability for apparent violations of Syria-related sanctions.
According to OFAC, in violation of Executive Order ("EO") 13582 ("Blocking Property of the Government of Syria and Prohibiting Certain Transactions with Respect to Syria") and EO 13382 ("Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters"), the bank:
- provided U.S. dollar services on behalf of sanctioned Syrian parties;
- indirectly conducted U.S.-cleared foreign exchange transactions on behalf of a sanctioned Syrian customer; and
- conducted letter of credit transactions, on behalf of sanctioned Syrian parties, that were processed through the U.S. financial system.
The bank voluntarily self-disclosed the apparent violations and, although the bank's actions conferred "substantial economic benefit" to sanctioned entities, OFAC concluded that the violations constituted a "non-egregious" case.
To settle the charges, the bank agreed to remit $8,572,500.
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