Emigrant Bank (Emigrant), a bank located in New York, has agreed to remit $31,867.90 to settle its potential civil liability for 30 apparent violations of the Iran sanctions administered by the Office of Foreign Assets Control (OFAC). For approximately 26 years, Emigrant maintained a Certificate of Deposit (CD) account on behalf of two individuals ordinarily resident and located in Iran, for which it processed 30 transactions between June 2017 and March 2021 totaling $91,051.13. Emigrant had actual knowledge of the Iranian address and apparent location of the accountholders during this period. The settlement amount reflects OFAC’s determination that Emigrant’s conduct was non-egregious and voluntarily self-disclosed.
Description of the Apparent Violations
In 1995, Emigrant opened a CD account (“the account”) for two Iranian residents, which it renewed every five years until it closed the account in 2021. During this period, the accountholders provided ample information to Emigrant indicating their Iranian residency, including letters from the accountholders to the bank showing their Iranian address and tax forms reflecting an address in Iran. Emigrant, in turn, demonstrated its knowledge of the Iranian residency and addresses through various documents, including an interest check, tax documents, periodic statements, and internal discussions and decisions.