Separately, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued a Finding of Violation to the parent company of wholly owned subsidiaries for 3,491 violations of the CACR and ITSR (collectively, the “Violations”).
OFAC has determined company voluntarily self-disclosed the Apparent Violations, and that the Apparent Violations constitute a non-egregious case. The total base penalty amount for the Apparent Violations was $955,750.
Beginning as early as 2003 or 2004, the company's business, based in Montreal, Canada engaged in a series of trade finance transactions that appear to have implicated the sanctions regulations administered by OFAC. These transactions generally involved importexport letters of credit for the company's Canadian customers that the bank failed to screen for any potential nexus to an OFAC-sanctioned country or entity prior to processing related transactions through the U.S. financial system. For a number of years, up to and including 2011, the bank maintained several accounts for, and processed transactions to or through the United States on behalf of, a Canadian company owned by a Cuban company.
To read the entire OFAC Press Release please follow this link: OFAC Violations