Sumitomo Mitsui Banking OFAC Settlement: $229.4K (2010)

From on or about December 9, 2005, until on or about December 1, 2006, SMBCNY appears to have violated the SSR when it exported services to Sudan through its processing of the payments for SMBC's purchase of six export bills, in an aggregate amount of $1,037,988, relating to letters of credit issued by Sudanese banks, and by its receipt of two USD payments, in the aggregate amount of $15,357,720, related to approximately forty letters of credit issued by a Sudanese bank.

OFAC determined that SMBC voluntarily self-disclosed the matter and that the alleged violations constituted a non-egregious case. The base penalty amount for the apparent violations is $655,373. The settlement amount of $229,380 reflects OFAC's consideration that SMBCNY is part of a commercially sophisticated international bank and had reason to know its conduct may have violated the SSR; SMBC has no violations of this nature on record with OFAC; SMBC substantially cooperated with OFAC's investigation of the alleged violations; and SMBC promptly responded to all requests for additional information and agreed to a statute of limitations tolling agreement when requested by OFAC.

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