On 4 January, OFAC advised that it had reached a settlement agreement with French bank, UBAF, with payment of $8,572,500 to settle its potential civil liability for 127 apparent violations of Syria-related sanctions. It is said that the majority of the apparent violations involved processing of internal transfers on behalf of Syrian entities that were followed by corresponding funds transfers through a US bank, and the remaining apparent violations were either “back-to-back” letter of credit transactions or other trade finance transactions involving sanctioned parties, all of which were processed through a US bank.
https://home.treasury.gov/system/files/126/01042021_UBAF.pdf
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