OFAC ANNOUNCES 2 SANCTIONS SETTLEMENTS – WITH MONEYGRAM AND WITH GERMAN SOFTWARE COMPANY

On 29 April, OFAC announced that it had agreed a settlement with MoneyGram Payment Systems Inc, the global payments company based in Dallas, Texas.  MoneyGram agreed to remit $34,328.78 to settle its potential civil liability for 359 apparent violations of multiple sanctions programmes.  it provided services to blocked individuals incarcerated in US federal prisons without a licence from OFAC, processed transactions on behalf of an additional blocked person, and processed transactions for individuals who initiated commercial transactions involving Syria. OFAC says that MoneyGram’s apparent violations were voluntarily self-disclosed and were non-egregious.

A separate agreement with SAP SE, a software company located in Walldorf, Germany, which has agreed to settle its potential civil liability for 190 apparent violations of the Iranian Transactions and Sanctions Regulations.  SAP engaged in the export, re-export, sale, or supply of technology or services from the US to companies in third countries with knowledge or reason to know the software or services were intended specifically for Iran, and sold cloud-based software subscription services accessed remotely through SAP’s cloud businesses in the US to customers that made the services available to their employees in Iran.  This agreement followed a self-disclosure by SAP.

https://home.treasury.gov/system/files/126/20210429_moneygram.pdf

https://home.treasury.gov/system/files/126/20210429_sap.pdf

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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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