On 17th September, the US Treasury announced a settlement with the British Arab Commercial Bank plc (BACB), a commercial bank located in the UK, and with no offices, business or presence under US jurisdiction.  It is said to have processed 72 apparent violations of the Sudanese Sanctions Regulations worth $190 million in 2010-14.  After consulting with the UK Prudential Regulation Authority, OFAC determined that the Bank’s would face disproportionate impact if required to pay the proposed penalty (over $228 million).  As a result, and in view of the fact that the bankt ceased the conduct, has entered into a settlement agreement, and on condition of maintaining its compliance commitments, BACB will remit only $4 million, with the balance of the proposed penalty suspended.

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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