Bank of Moscow OFAC Settlement: $9.5M (2014)

On October 25, 2007, OFAC designated Bank Melli Iran ZAO, Moscow, Russia ("BMI Russia") pursuant to E.O. 13382. From January 9, 2008, to July 13, 2009, Bank of Moscow sent 69 funds transfers totaling $41,306,113 for or on behalf of BMI Russia that were processed to or through the United States. None of the Society for Worldwide Interbank Financial Telecommunication ("SWIFT") payment messages sent by Bank of Moscow in connection with these funds transfers included specific references to "Melli," "Iran," or BMI Russia's SWIFT Business Identifier Code, but instead identified the bank through abbreviations such as "BMICJSCMOSCOWRUSSIA" (a reference to Bank Melli Iran Closed Joint Stock Company Moscow Russia) or "BMI CJSC." U.S. financial institutions processed all 69 of the funds transfers straight through without manual intervention.

Bank of Moscow did not voluntarily self-disclose the alleged violations, and the alleged violations constitute a non-egregious case. The total base penalty amount for the alleged violations was $14,063,000. OFAC considered the facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A, resulting in a settlement amount of $9,492,525.

This enforcement action highlights the particular sanctions risk faced by foreign financial institutions that maintain accounts for persons subject to OFAC sanctions and conduct significant business through the U.S. financial system.

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