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- OFAC administers and enforces economic sanctions against targeted foreign countries, regimes, terrorists, international narcotics traffickers, and proliferation of weapons of mass destruction among others. OFAC acts under Presidential national emergency authorities, as well as authority granted by specific legislation, to impose controls on transactions and freeze assets under U.S. jurisdiction.
SCB is a financial institution registered and organized under the laws of England and Wales.
II. APPARENT VIOLATIONS
- OFAC conducted an investigation of SCB in connection with thousands of transactions SCB processed to or through the United States in apparent violation of primarily the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 ("ITSR"), as well as a number of payments that implicated the now-regulated Sudanese Sanctions Regulations, 31 C.F.R. Part 538 ("SSR"), the Syrian Sanctions Regulations, 31 C.F.R. Part 542 ("SySR"), or Executive Order 13582 of August 17, 2011, "Blocking Propoerty of the Government of Syria and Prohibiting Certain Transactions With Respect to Syria" (E.O. 13582), the now-repealed Burmese Sanctions Regulations, 31 C.F.R. Part 537 ("BSR"), and the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (the "Apparent Violations").
- OFAC determined that SCB did not voluntarily disclose the Apparent Violations, and that the Apparent Violations constitute an egregious case.