THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

Issue 57, February 2017

Canadian bank faces penalties for OFAC violations and lack of OFAC compliance programme

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By Timothy O’Toole, Miller Chevalier www.millerchevalier.com   On 13 January 2017, the Office of Foreign Assets Control (‘OFAC’) of the U.S. Department of the Treasury  issued an enforcement action against Toronto-Dominion Bank (‘TD Bank’), a Canadian company and its Luxembourg-based subsidiaries, that involved apparent violations of the Cuban Assets Control Regulations (the ‘CACR’) and the Iranian Transactions and Sanctions Regulations (the ‘ITSR’). The group of apparent violations all stem from the activity of TD Bank’s Canadian operation. First, TD Bank failed to screen U.S.$1.165m dollars of transactions for ‘any potential nexus to an OFAC-sanctioned country or entity prior to processing...

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