Société Générale OFAC Settlement: $111.4K (2011)

OFAC alleged that SGNY dealt in Iranian-origin services and/or facilitated transactions by a foreign person where the transactions by the foreign person would have been prohibited by the Regulations if performed by a United States person. Specifically, OFAC alleged that SGNY, as the issuing bank of two letters of credit between two non-sanctioned parties, processed two payments under those letters of credit involving the shipment of cargo transported aboard vessels owned and/or managed by the Islamic Republic of Iran Shipping Lines of Tehran, Iran, an Iranian entity. The transactions occurred on or about December 27, 2006, and on or about May 9, 2007. The value of the payments was $329,954.

SGNY voluntarily self-disclosed the alleged violations, and OFAC determined that the alleged violations constituted a non-egregious case. The base penalty amount for the alleged violations was $164,977. The settlement amount of $111,359 reflects OFAC's consideration of General Factors under OFAC's Economic Sanctions Enforcement Guidelines.

SGNY improved its compliance program in response to the apparent violations by enhancing its internal controls related to screening trade finance transactions, and provided additional training to staff involved in processing such transactions.

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