Commerzbank OFAC Settlement: $175.5K (2011)

From on or about September 7, 2005, through on or about September 30, 2005, Commerzbank, acting as an advising and confirming bank in connection with a letter of credit, presented four sets of trade documents to the Miami branch of the foreign bank that issued the letter of credit, for payment in favor of a Canadian company. A Cuban Specially Designated National had an interest in those trade documents. The aggregate value of the trade documents was $884,157.

Commerzbank did not voluntarily self-disclose the matter, and the alleged violations constituted a non-egregious case. The base penalty amount totaled $260,000. The settlement amount of $175,500 reflects OFAC's consideration of the following facts and circumstances under the General Factors of OFAC's Economic Sanctions Enforcement Guidelines: Commerzbank should have been aware of the prohibited Cuban interest, given that the trade documents contained repeated references to the SDN and its vessels; Commerzbank undertook remedial measures to strengthen its OFAC compliance program to ensure that such apparent violations do not recur; and Commerzbank cooperated with OFAC's investigation, including by agreeing to toll the statute of limitations.

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