IN JANUARY 2017, the U.S. Treasury
Department, Office of Foreign Assets Control (OFAC)
announced a settlement with a large Canadian bank for
approximately 170 alleged violations of U.S. sanctions against
Iran and Cuba. The bank agreed to pay OFAC more than $500,000 in
On the same day, OFAC announced its determination that two of the bank’s
European subsidiaries had committed nearly 3,500 U.S. sanctions violations. Yet OFAC
imposed no penalty on the subsidiaries.
This is not the only example of OFAC imposing different penalties against
entities apparently involved in similar conduct. In September 2016, OFAC
U.S. sanctions on Iran. The number of violations that each company
allegedly committed was similar; the penalty was not, as one
company paid 1/100th of what the other company paid.
BY THAD MCBRIDE