OFAC fines Saudi bank for Sudan/Syria sanctions violations

National Commercial Bank (NCB) agreed to pay $653,347 to resolve 13 apparent sanctions violations. OFAC deemed the case to be “non-egregious.”

The 13 U.S. dollar transactions totaled approximately $5.9 million and were processed by NCB between November 2011 and August 2014, OFAC stated in its Web notice. The transactions either benefitted Sudanese/Syrian companies or involved goods transiting through those countries—a violation of sanction rules at the time.

Of the apparent violations, eight related to Syria and five to Sudan. NCB only self-disclosed the Syria violations, according to OFAC.

The agency noted the apparent violations occurred after NCB had made efforts to improve its sanctions compliance program in late 2011. Further compliance enhancements the bank has made since include replacing its board of directors, aligning payment message policies with Basel and Financial Action Task Force recommendations, and the implementation of an anti-money laundering department tasked with sanctions compliance and countering illicit finance.

“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,” OFAC stated.

In June 2018, OFAC eased sanctions targeting Sudan in recognition of positive efforts made in the region and improved cooperation with the United States. Syria largely remains sanctioned under Executive Order 13582, which prohibits “the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any services to Syria.”