Bank of China (UK) OFAC Settlement: $2.3M (2021)

Last updated: July 20, 2026

Bank of China (UK) Limited ("BOC UK") settled with OFAC for $2,329,991 to resolve apparent violations of the Sudanese Sanctions Regulations arising from its processing of transactions through the U.S. financial system on behalf of parties in Sudan. Between September 4, 2014 and February 24, 2016, BOC UK processed 111 commercial transactions totaling $40,599,184 in apparent violation of OFAC's now-repealed Sudan sanctions program, which prohibited the exportation, directly or indirectly, to Sudan of any goods, technology, or services from the United States. OFAC determined that the apparent violations were voluntarily self-disclosed and constituted a non-egregious case.

Penalty Amount

$2,329,991.00

Enforcement Date

August 26, 2021

Rank in Top Penalties

#78

Case Details

Type:: Entity
Name:: Bank of China (UK) Limited
Country:: 🇬🇧 United Kingdom
Industry:: Banking
Address:: London, the United Kingdom
Penalty amount:: $2,329,991.00
Base civil monetary penalty:: $4,314,799.00
Max civil monetary penalty:: $99,411,550.00
Egregious case:: No
Apparent violations:: 111
Voluntary self disclosure:: Yes
Case:: Settlement
Violation period:: September 4, 2014 to February 24, 2016
Program:: Sudanese Sanctions Regulations (SSR), 31 C.F.R. § 538.205
Enforcement date:: August 26, 2021

Nature of the Apparent Violations

As a result of an internal investigation triggered by a Sudanese customer's request to process a payment, BOC UK conducted a lookback review that identified two customers who had engaged in Sudan-related transactions processed through the U.S. financial system.

One customer was an entity incorporated outside of Sudan that maintained a branch in Sudan that, in 2014, became the instructing party and account signatory to transactions processed by BOC UK on behalf of the entity. Written communications from that customer contained references to the location of the branch in Sudan. BOC UK also processed certain transactions to recipients which appeared to be in Sudan at the time. The other customer was a Sudanese subsidiary of an entity also incorporated outside of Sudan. The information provided by the subsidiary to BOC UK as part of the bank's know-your-customer documentation identified the subsidiary as being registered in Sudan.

In relation to both customers, BOC UK's internal customer database did not include reference to Sudan in the name or address fields of either customer. Accordingly, SWIFT messages processed for those customers by BOC UK through U.S. banks did not include any references to Sudan.

These compliance deficiencies resulted from BOC UK's staff's failure to appropriately evaluate and escalate potential transactions with underlying account and transactional documentation indicating ties to Sudan. Consequently, BOC UK processed 111 payments via U.S. correspondent banks between September 4, 2014 and February 24, 2016 totaling $40,599,184 in apparent violation of the Sudanese Sanctions Regulations (SSR), 31 C.F.R. § 538.205.

How OFAC Determined the Penalty

The statutory maximum civil monetary penalty applicable in this matter is $99,411,550. OFAC determined that BOC UK voluntarily self-disclosed the Apparent Violations and the Apparent Violations constitute a non-egregious case. Accordingly, under OFAC's Economic Sanctions Enforcement Guidelines, the base civil monetary penalty amount applicable in this matter is $4,314,799. The settlement amount of $2,329,991 reflects OFAC's consideration of the General Factors under the Enforcement Guidelines.

Aggravating Factors

BOC UK demonstrated a reckless disregard for U.S. sanctions requirements by processing transactions through the U.S. financial system for entities in Sudan despite having account and transactional information indicating the Sudanese connection to the accounts and in contravention of the bank's existing policies and procedures.
Certain personnel processing the transactions at BOC UK were aware that the payments were related to the entities in Sudan.
For at least one and a half years, BOC UK conferred economic benefit to a then comprehensively sanctioned country by processing 111 outgoing payments totaling approximately $40.6 million.
BOC UK is a commercially sophisticated financial institution that processes transactions internationally.

Mitigating Factors

BOC UK has no prior sanctions history, including having not received a Penalty Notice or Finding of Violation from OFAC in the five years preceding the earliest date of the transactions giving rise to the Apparent Violations.
BOC UK self-identified, and then cooperated with OFAC's investigation into, the Apparent Violations by conducting a lookback and by entering into a statute of limitations tolling agreement.
BOC UK represented to OFAC it has undertaken several remedial measures since the identification of the Apparent Violations, including: establishing an executive level committee responsible for implementation of compliance policies and procedures, which ultimately reports to the Board of Directors; conducting an annual enterprise-wide sanctions risk assessment by business line, which incorporates monitoring of risks and internal audit testing and integrates input from external consultants; applying a centralized customer due diligence function firm-wide to strengthen internal controls; customizing firm-wide staff training on sanctions compliance based on the employee's tenure and business line; and enhancing policies and procedures to better address U.S. sanctions regulations applicable in processing payments through the United States.

Compliance Takeaways

This case highlights the importance of ensuring that know-your-customer information is integrated holistically throughout internal databases that inform compliance decisions and that potential sanctions concerns are appropriately flagged and escalated when a sanctions nexus may be present.

Official Source Documents

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Archived on June 13, 2026

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