The National Commercial Bank OFAC Settlement: $653.3K

Last updated: July 20, 2026

The National Commercial Bank (NCB), a bank headquartered in Saudi Arabia, settled its potential civil liability for 13 apparent violations of the Sudanese Sanctions Regulations, 31 C.F.R. § 538.205, and section 2(b) of Executive Order 13582, by agreeing to remit $653,347. The apparent violations related to transactions involving Sudan or Syria that transited through the U.S. financial system, processed between November 7, 2011 and August 28, 2014.

Penalty Amount

$653,347.00

Enforcement Date

December 28, 2020

Rank in Top Penalties

#126

Case Details

Type:: Entity
Name:: The National Commercial Bank
Country:: 🇸🇦 Saudi Arabia
Industry:: Banking
Address:: Jeddah, Saudi Arabia
Penalty amount:: $653,347.00
Base civil monetary penalty:: $1,814,854.00
Max civil monetary penalty:: $12,111,632.00
Egregious case:: No
Apparent violations:: 13
Voluntary self disclosure:: Partial
Case:: Settlement
Violation period:: November 7, 2011 to August 28, 2014
Program:: Sudanese Sanctions Regulations ("SSR"), 31 C.F.R. § 538.205section 2(b) of Executive Order (E.O.) 13582 of August 17, 2011
Enforcement date:: December 28, 2020

Nature of the Apparent Violations

Between November 7, 2011 and August 28, 2014, NCB processed, directly or indirectly, 13 U.S. dollar (USD) transactions totaling $5,918,560 to or through the United States in circumstances where a benefit of NCB's service was received by Sudanese or Syrian counterparties, or that involved goods originating in or transiting through Sudan or Syria. None of the Sudanese or Syrian parties was a customer of NCB. These transactions were in apparent violation of the Sudanese Sanctions Regulations (SSR), 31 C.F.R. § 538.205, and section 2(b) of Executive Order (E.O.) 13582 of August 17, 2011, respectively. The apparent violations began in late 2011, after NCB had started to implement more robust compliance measures intended to modernize and upgrade its compliance controls, including those relating to sanctions screening and OFAC sanctions compliance.

How OFAC Determined the Penalty

The statutory maximum civil monetary penalty applicable in this matter is $12,111,632. OFAC determined that the apparent violations constitute a non-egregious case. NCB voluntarily self-disclosed the eight Syria-related apparent violations but did not voluntarily self-disclose the five Sudan-related apparent violations. Accordingly, under OFAC's Economic Sanctions Enforcement Guidelines, the base civil monetary penalty amount applicable in this matter is $1,814,854. The settlement amount of $653,347 reflects OFAC's consideration of the General Factors under the Enforcement Guidelines.

Aggravating Factors

NCB conferred substantial economic benefit to U.S.-sanctioned parties and caused significant harm to the integrity of U.S. sanctions programs and their associated policy objectives by allowing sanctioned parties to conduct business in or through the United States for a number of years.
NCB is a large and commercially sophisticated financial institution.

Mitigating Factors

NCB did not act with willful intent to violate U.S. sanctions law or with a reckless disregard for its U.S. sanctions obligations.
NCB has no prior sanctions history, including having not received a penalty notice or Finding of Violation from OFAC in the five years preceding the date of the earliest transaction giving rise to the apparent violations.
NCB cooperated with OFAC's investigation into the apparent violations, including by conducting an extensive transaction review and entering into a statute of limitations tolling agreement with multiple extensions.
Most of the Syria-related apparent violations occurred shortly after the imposition of relevant prohibitions.
NCB enhanced compliance controls in response to past weaknesses and the subsequent apparent violations, including: replaced its Board of Directors and senior executives and enhanced its compliance program by implementing new sanctions screening software and new training procedures for bank personnel; implemented internal policies that require payment and non-payment messages to be transparent, in line with Basel requirements and FATF recommendations, and that prohibit the omission, deletion or alteration of information in the payment messages or orders; required screening of all payments against international sanctions lists, including OFAC lists; implemented an Anti-Money Laundering Department tasked with sanctions compliance and countering illicit finance, including money laundering and terrorist financing; required prospective customer account openings to be subjected to substantial due diligence, including Compliance Department approval of any account opening, and restricted account openings to only residents of Saudi Arabia; and prohibited the opening of USD accounts for any Sudanese customers or financial institutions.

Compliance Takeaways

This enforcement action highlights the importance of ensuring that sanctions compliance policies and procedures address both direct and indirect sanctions compliance risks, and in particular, highlights the importance of implementing strong remedial measures in response to sanctions program lapses.

Official Source Documents

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Provided for informational purposes only and does not constitute legal or compliance advice. Always consult the source document directly rather than relying on this summary.

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Archived on June 13, 2026

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