On June 14, 2012, the Office of Foreign Assets Control (OFAC) announced that the National Bank of Abu Dhabi (NBAD) agreed to remit $855,000 to settle potential civil liability for 45 transactions that may have violated the Sudanese Sanctions Regulations. The apparent violations occurred between November 2004 and December 2005. NBAD provided information to OFAC revealing that certain of its clerical staff removed or omitted Sudan-related references in payment instructions processed on behalf of its Sudan branch for payments routed through financial institutions located in the United States. Such routing was in violation of the prohibition against the “exportation or re-exportation, directly or indirectly, to Sudan… of services from the United States,” as set forth in the Sudan Sanctions Regulations. The combined value of the 45 electronic funds transfers was $4,389,235.
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