OFAC Penalizes Two Foreign Banks in One Week for U.S. Sanctions Violations: Key Takeaways

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued two penalties against non-U.S. financial institutions this past week. The agency’s December 28, 2020 settlement with Saudi Arabia-based National Commercial Bank (NCB) and its January 4, 2021 settlement with France-based Union de Banques Arabes et Françaises (UBAF) arguably demonstrate a more detailed evaluation by OFAC of compliance procedures and activities of foreign financial institutions processing U.S. dollar (USD) payments. Additionally, they may potentially signal more enforcement actions against foreign financial institutions going forward.

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued two penalties against non-U.S. financial institutions this past week. The agency’s December 28, 2020 settlement with Saudi Arabia-based National Commercial Bank (NCB) and its January 4, 2021 settlement with France-based Union de Banques Arabes et Françaises (UBAF) arguably demonstrate a more detailed evaluation by OFAC of compliance procedures and activities of foreign financial institutions processing U.S. dollar (USD) payments. Additionally, they may potentially signal more enforcement actions against foreign financial institutions going forward.

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