Finding of Violation for Sudanese Sanctions Regulations violations (London branch payments 2005-2009)
OFAC issued a Finding of Violation, without a civil monetary penalty, because Mashreq's London branch processed 1,760 outgoing USD payments for offshore accounts of Sudanese banks between January 2005 and February 2009 without identifying the Sudanese originators. OFAC cited recklessness, senior-level knowledge at the branch and weak controls, and as mitigation cooperation, a statute of limitations waiver, the end of the conduct years before the 2015 investigation, and remediation. It was part of a global settlement with NYDFS and the Federal Reserve.
OFAC determined the appropriate administrative action in this matter was a FOV in lieu of a civil monetary penalty
Per OFAC: compliance staff increased by over 400% since 2007, Sudanese bank USD accounts closed 15 January 2009, automated screening, over USD 122 million spent on compliance over four years with a further USD 40 million planned.
