National Bank of Pakistan OFAC Settlement: $28.8K

Last updated: July 20, 2026

The National Bank of Pakistan's New York Branch settled potential civil liability for seven apparent violations of the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594, agreeing to remit $28,800 to OFAC. The apparent violations involved funds transfers processed by the branch that were originated by, or destined for, the account of a party designated pursuant to Executive Order 13224.

Penalty Amount

$28,800.00

Enforcement Date

June 18, 2015

Rank in Top Penalties

#363

Case Details

Type:: Entity
Name:: National Bank of Pakistan's New York Branch
Country:: 🇺🇸 United States
Industry:: Banking
Address:: New York
Penalty amount:: $28,800.00
Base civil monetary penalty:: $64,000.00
Egregious case:: No
Apparent violations:: 7
Voluntary self disclosure:: No
Case:: Settlement
Violation period:: June 6, 2013 to January 31, 2014
Program:: Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
Enforcement date:: June 18, 2015

Nature of the Apparent Violations

On May 31, 2013, OFAC designated Kyrgyz Trans Avia, an airline headquartered in Bishkek, Kyrgyzstan, pursuant to Executive Order 13224 of September 23, 2001, "Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism." Between June 6, 2013 and January 31, 2014, NBP New York processed seven funds transfers totaling $55,952.14 that were originated by, or destined for, the account of "LC Aircompany Kyrgyztransavia" at the National Bank of Pakistan's branch in Bishkek, Kyrgyzstan ("NBP Bishkek"). NBP New York's OFAC interdiction filter failed to generate an alert or identify any potential matches to OFAC's List of Specially Designated Nationals and Blocked Persons when it screened the funds transfers for review, and the bank processed all seven of the transactions forward. The seven transactions constitute apparent violations of § 594.201 of the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594.

How OFAC Determined the Penalty

OFAC determined that NBP New York did not voluntarily self-disclose the apparent violations and that the apparent violations constitute a non-egregious case. The total base penalty amount for the apparent violations was $64,000. The settlement amount of $28,800 reflects OFAC's consideration of the facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

Aggravating Factors

NBP New York processed seven transactions involving an SDN, five of which conferred economic benefit to a sanctioned party and resulted in harm to the sanctions program objectives of the GTSR
NBP New York is a sophisticated financial institution
NBP New York's OFAC interdiction filter failed to generate an alert to an SDN in seven separate transactions

Mitigating Factors

No NBP New York managers or supervisors were aware of the conduct that led to the apparent violations
NBP New York has not received a penalty notice or Finding of Violation from OFAC in the five years preceding the earliest date of the apparent violations
NBP New York took appropriate remedial action in response to the apparent violations and took steps to enhance its OFAC interdiction filter
NBP New York cooperated with OFAC's investigation

Compliance Takeaways

This enforcement action highlights the particular sanctions risk faced by the U.S. locations of foreign financial institutions that maintain accounts for persons subject to OFAC sanctions.

Official Source Documents

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Archived on June 13, 2026

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