![]() What makes this settlement agreement notable is that OFAC also cited a number of Euro-denominated payments involving Iranian parties as apparent violations. sanctions regulations applicable to financial institutions without a physical presence in the United States." In one regard, First Bank’s “lack of understanding” was typical of what is seen in many other OFAC settlement agreements with foreign banks operating outside the US: First Bank processed trade finance transactions involving Iran and Syria in apparent violation of OFAC’s regulations because the payments were US-dollar denominated and transited the US financial system. According to Treasury, these apparent violations resulted from "First Bank's lack of understanding of the scope of U.S. Specifically, JC Flowers and First Bank agreed to pay Treasury more than $850,000 to settle civil penalties associated with 98 commercial transactions that may have violated Treasury's Office of Foreign Assets Control (OFAC)'s Iran and Syria sanctions programs. (JC Flowers), resulting from financial services First Bank provided to parties located in Iran and Syria. ![]() ![]() ![]() On August 27, 2021, the US Department of the Treasury (Treasury) announced that it had reached a settlement agreement (the Settlement Agreement) with Romanian bank First Bank SA (First Bank) and its US parent company, JC Flowers & Co. ![]()
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