National Australia Bank Ltd. OFAC Settlement: $100K

The alleged violations involved the processing of several transactions through the United States under the Burmese Sanctions Regulations, 31 C.F.R. Part 537, the Sudanese Sanctions Regulations, 31 C.F.R. Part 538, and the Cuban Assets Control Regulations, 31 C.F.R. Part 515, between November 2003 and December 2005. Some of the transactions were processed through NAB's branch in New York City, but the majority were processed through correspondent accounts held by it at other U.S. banks.

The transactions were voluntarily disclosed to OFAC following an extensive review by NAB of all of its transactions that were processed through the United States during this time period. Due to the significant remediation taken by the bank, including major upgrades to its worldwide compliance policies, as well as the fact that the violations were voluntarily disclosed, OFAC mitigated the potential penalties for these transactions by nearly 90%, resulting in a $100,000 settlement.

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