U.S. company to pay $1.4 million to settle 2,260 violations of sanctions

Potential civil liability for apparent violations totaling over $802,000

Potential civil liability for apparent violations totaling over $802,000

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) today announced that a U.S. company has agreed to pay approximately $1.4 million to settle its potential civil liability for 2,260 apparent violations, totaling over $802,000, and made in violation of multiple U.S. sanctions.

According to today’s OFAC release [PDF 208 KB], the company—a publicly traded New York-based online money transmitter and provider of prepaid access—processed between February 2013 and February 2018:

  • 2,241 payments for parties located in certain jurisdictions and regions subject to sanctions including the Crimea region of Ukraine, Iran, Sudan, and Syria
  • 19 payments on behalf of sanctioned persons on OFAC’s list of specially designated nationals and blocked persons (SDN list)

The company’s sanctions compliance program deficiencies at the relevant times—including its screening, testing, auditing, and transaction review procedures—enabled persons in the identified jurisdictions and on the SDN list to engage in approximately $802,000 worth of transactions.

OFAC determined that:

  • The 2,241 payments were not voluntarily self-disclosed.
  • The 19 payments regarding the SND list were voluntarily self-disclosed.
  • All transactions were non-egregious.

For more information on this topic or to learn more about KPMG’s Trade & Customs Services, contact:

Doug Zuvich
Partner and Global Practice Leader
T: 312-665-1022
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
T: 267-256-2614
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
T: 631-425-6057
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
T: 415-963-7861
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
T: 212-954-3094
E: labad@kpmg.com

Irina Vaysfeld
T: 212-872-2973
E: ivaysfeld@kpmg.com

Amie Ahanchian
T: 202-533-3247
E: aahanchian@kpmg.com

Christopher Young
T: 312-665-3229
E: christopheryoung@kpmg.com

Gisele Belotto
Managing Director
T: 305-913-2779
E: gbelotto@kpmg.com

George Zaharatos
T: 404-222-3292
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
T: 313-230-3080
E: adoornaert@kpmg.com

Jessica Libby
Managing Director
T: 612-305-5533
E: jlibby@kpmg.com

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