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Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Deutsche Bank Trust Company Americas

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced two settlements totaling $583,100 with Deutsche Bank Trust Company Americas (DBTCA).  The settlements resolve OFAC’s investigations into apparent violations of the Ukraine-Related Sanctions Regulations.  Specifically, DBTCA agreed to pay $157,500 for processing a large payment, related to a series of purchases of fuel oil, through the United States that involved a property interest of a designated oil company in Cyprus.  At the time it processed the payment, DBTCA had reason to know of the designated oil company’s potential interest, but did not conduct sufficient due diligence to determine whether the designated oil company’s interest in the payment had been extinguished.  Separately, DBTCA agreed to remit $425,600 for processing payments destined for accounts at a designated financial institution.  DBTCA failed to stop the 61 payments because it had not included in its sanctions screening tool the designated financial institution’s Society for Worldwide Interbank Financial Telecommunication (SWIFT) Business Identifier Code (BIC), and DBTCA’s screening tool was calibrated so that only an exact match to a designated entity would trigger further manual review.  OFAC determined that neither case was voluntarily self-disclosed to OFAC, and that the apparent violations constitute non-egregious cases.

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