OFAC Fines Saudi Bank for Sanctions Violations
The Office of Foreign Assets Control fined a Saudi bank more than $650,000 for violating U.S. sanctions against Sudan and Syria, a Dec. 28 notice said. OFAC said Saudi Arabia-based National Commercial Bank (NCB) illegally processed 13 transactions worth nearly $6 million.
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Between 2011 and 2014, NCB processed the payments through the U.S. to benefit Sudanese or Syrian “counterparties” or involving goods “originating in or transitioning” through Sudan or Syria, OFAC said. OFAC said none of the Sudanese or Syrian parties was an NCB customer, and said the bank’s violations constituted a non-egregious case. The violations began after the bank implemented a “more robust compliance” program intended to modernize and upgrade its compliance controls, including those related to sanctions screening.
NCB voluntarily disclosed the eight Syria-related violations but not the five Sudan-related violations. Aggravating factors included that NCB “conferred substantial economic benefit” to U.S.-sanctioned parties, harmed U.S. sanctions programs and is a “large and commercially sophisticated financial institution.”
Mitigating factors included that NCB did not act with “willful intent” to violate U.S. sanctions, had no prior sanctions history, cooperated with OFAC’s investigation and committed the violations “shortly” after OFAC imposed the regulations. The agency also said the bank increased its compliance and screening controls, replaced its board of directors and senior executives, implemented an anti-money laundering department and will block the opening of U.S. dollar accounts for any Sudanese customers.