OFAC SETTLEMENT WITH DEUTSCHE BANK TRUST COMPANY AMERICAS FOR APPARENT VIOLATIONS OF UKRAINE-RELATED SANCTIONS

On 9 September, a news release from OFAC advised that it had reached a settlement with Deutsche Bank over apparent violations of sanctions relating to Ukraine and the annexation of Crimea.  The total to be paid by the bank is $583,100.  The violations related to a series of purchases of fuel oil, through the US that involved a property interest of a designated oil company in Cyprus; and a failure to stop 61 payments destined for the accounts of a designated financial institution.  The latter violations occurred because the bank had not included in its sanctions screening tool the designated financial institution’s SWIFT Business Identifier Code (BIC) and its screening tool was calibrated so that only an exact match to a designated entity would trigger further manual review.

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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