Mashreqbank PSC

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.

Consent cease and desist order on sanctions compliance at offices outside the United States

The Federal Reserve announced a consent cease and desist order against Mashreqbank psc for insufficient policies and procedures to ensure that activities at its offices outside the United States complied with US sanctions laws, taken in conjunction with OFAC and NYDFS. The release states no penalty amount.

insufficient policies and procedures to ensure that the activities conducted at its offices outside the United States

Consent order for processing Sudan-related US dollar payments in breach of sanctions

The New York State Department of Financial Services found that between 2005 and 2009 Mashreqbank PSC processed more than USD 4 billion of payments connected to Sudan through its New York branch, concealing the link by leaving payment message fields empty, and that the branch processed about USD 2.5 million more between 2010 and 2014. The bank did not report the conduct to DFS until 2015. Under the consent order it paid a USD 100 million penalty and must report on its OFAC compliance programme, and DFS acknowledged its substantial cooperation and remediation.