The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $5,263,171 settlement with JPMorgan Chase Bank, N.A., to settle potential civil liability for 87 apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (CACR); the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR); and the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. Part 544 (WMDPSR). Specifically, the transactions were net settlement payments, of which a very small portion appears to have been attributable to interests of airlines that were at various times on OFAC’s List of Specially Designated Nationals and Blocked Persons (the “SDN List”), blocked pursuant to OFAC sanctions, or located in countries subject to the sanctions programs administered by OFAC. These apparent violations do not include transactions that were exempt from the prohibitions of the International Emergency Economic Powers Act (IEEPA); for example, the apparent violations include transactions such as airline freight charges, which are not exempt. OFAC has determined that JPMC voluntarily self-disclosed the apparent violations, and that the apparent violations constitute a non-egregious case.
Separately, OFAC has issued a Finding of Violation to JPMC regarding violations of the Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598 (FNKSR), and the Syrian Sanctions Regulations, 31 C.F.R. part 542. Specifically, OFAC determined that between August 4, 2011 and April 29, 2014, JPMC processed 85 transactions totaling $46,127.04 and maintained eight accounts on behalf of six customers who were contemporaneously identified on the SDN List. OFAC determined that JPMC voluntarily disclosed the violations, and that the violations constitute a non-egregious case.
For more information on these actions, please visit this web notice.