Trans Pacific National Bank OFAC Settlement: $12.5K

OFAC alleged that Trans Pacific engaged in transactions or dealings in or related to goods of Iranian origin and services for exportation to Iran, and facilitated transactions by a foreign person where the transactions by the foreign person would be prohibited by the Iranian Transactions Regulations, 31 C.F.R. part 560, if performed by a United States person. Trans Pacific initiated two separate wire transfers on behalf of an account holder for an underlying commercial transaction prohibited by the Regulations. The transactions occurred on or about September 18, 2007, and on or about March 19, 2008. In one instance, the wire transfer instructions referenced "Iranian material" and in the other instance the instructions referenced "Iran material." The value of the transactions totaled $35,600.

Trans Pacific did not voluntarily disclose this matter to OFAC. The base penalty amount was $50,000. The $12,500 settlement amount reflects that Trans Pacific's filtering system was not designed to detect references to sanctions targets in the "Originator to Beneficiary Information" field, leading to both apparent violations; that Trans Pacific enhanced its compliance program in response by requiring memorandum information of each wire transfer to be reviewed for OFAC sanctions references and strengthened its escalation procedures in the event of a possible OFAC sanctions reference; and that Trans Pacific had not been subject to prior OFAC enforcement action and fully cooperated with OFAC's investigation.

The apparent violations arose because Trans Pacific's filtering system was not designed to detect references to sanctions targets in the "Originator to Beneficiary Information" field of wire transfers — a gap that allowed two prohibited transactions to pass through despite containing explicit references to Iran in the wire instructions. In response, Trans Pacific required that the memorandum information of each wire transfer also be reviewed for OFAC sanctions references, and strengthened its escalation procedures in the event of a possible OFAC sanctions reference.

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