National Bank of Abu Dhabi OFAC Settlement: $855K

In response to inquiries made by OFAC related to certain transactions, NBAD provided information revealing that certain of its clerical staff removed or omitted Sudan-related references in payment instructions processed on behalf of its Sudan branch for payments routed through financial institutions located in the United States. This conduct constituted apparent violations of the prohibition against the "exportation or re-exportation, directly or indirectly, to Sudan… of services from the United States," 31 C.F.R. § 538.205. The 45 electronic funds transfers had a combined value of $4,389,235.42 and occurred from on or about November 11, 2004, to on or about December 27, 2005.

NBAD did not voluntarily self-disclose the apparent violations. OFAC determined that the apparent violations constituted a non-egregious case. The base penalty amount was $4,276,000. The settlement amount of $855,000 reflects OFAC's consideration of the following General Factors under OFAC's Economic Sanctions Enforcement Guidelines: NBAD took prompt and appropriate remedial action; NBAD provided substantial cooperation throughout OFAC's review; and NBAD had not received a penalty notice or finding of violation in the five years preceding the transactions at issue.

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