Citigroup Inc. OFAC Settlement: $217.8K (2014)

The eight apparent violations fall into two groups. Between April 2, 2009, and November 16, 2009, Citigroup Trade Services Malaysia (Citi Penang) processed four export bill collection applications totaling $638,074.15 on behalf of Citibank N.A., Hong Kong, involving the shipment of goods to Iran. In two of those instances, the shipments involved the Islamic Republic of Iran Shipping Lines (IRISL), which OFAC designated on September 10, 2008, pursuant to Executive Order 13382 of June 28, 2005, "Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters." Although the bank had documentation in its possession related to the export bill collections that contained references to Iran and IRISL, Citi Penang operators did not review or screen the bills of lading, certificates of origin, or shipment advice which contained those references.

Separately, on February 9, 2010, January 12, 2011, March 8, 2011, and October 29, 2012, Citibank processed four funds transfers totaling $133,786.73 involving entities appearing on OFAC's List of Specially Designated Nationals and Blocked Persons (the SDN List). Citibank's interdiction software did not identify references to the sanctioned parties in the payment instructions, and the bank processed the payments straight through without manual intervention. For example, Citibank received and processed a funds transfer initiated by a third-country financial institution's customer, Higher Institute for Applied Science and Technology, despite an SDN List entry for an entity named Higher Institute of Applied Science and Technology at the time of the transaction.

OFAC determined that Citigroup voluntarily self-disclosed the four apparent violations processed by Citi Penang, but did not voluntarily self-disclose the apparent violations processed by Citibank. OFAC also determined that the apparent violations constitute a non-egregious case. The base penalty amount was $484,091. The settlement amount of $217,841 reflects OFAC's consideration of the relevant facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

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