OFAC and JPMorgan Chase agree $5m settlement

The US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’) has announced a $5,263,171 settlement with JPMorgan Chase Bank (‘JPMC’) for ‘apparent’ sanctions violations (4 October).

The 87 transactions in question were net settlement payments of which ‘a very small proportion…appeared’ to be attributable to airlines named on OFAC’s Specially Designated Nationals (‘SDN’) list or located in countries blocked by OFAC’s sanctions programmes.

The payments were potential violations of the Cuban Asset Control Regulations (‘CACR’), the Iranian Transactions and Sanctions Regulations (‘ITSR’) and the Weapons of Mass Destruction Proliferators Sanctions Regulations (‘WMDPSR’). JPMC voluntarily self-disclosed the apparent violations.

OFAC also issued a separate Finding of Violation to JPMC over the processing of 85 transactions totalling $46,127.04 and the maintenance of six customer accounts between 2001 and 2014 involving persons on the SDN List, contrary to the Foreign Narcotics Kingpin Sanctions Regulations (‘FNKSR’) and the Syrian Sanctions Regulations.

JPMC previously paid a $88.3m settlement to OFAC in 2011 for ‘apparent violations’ of sanctions against Cuba, Sudan, Liberia and Iran for transactions between March 2005 and March 2011, which included for 1,711 transfers to Cubans.

See OFAC’s Notice:

https://www.treasury.gov/resource-center/sanctions/CivPen/Documents/jpmc_10050218.pdf