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ENFORCEMENT INFORMATION FOR JUNE 18, 2015
National Bank of Pakistan, New York Settles Potential Liability for Apparent Violations of the Global Terrorism Sanctions Regulations: The National Bank of Pakistan’s New York Branch ("NBP New York") has agreed to remit $28,800 to settle potential civil liability for seven apparent violations of § 594.201 of the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (the GTSR).
On May 31, 2013, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Kyrgyz Trans Avia, an airline headquartered in Bishkek, Kyrgyzstan, pursuant to Executive Order 13224 of September 23, 2001, "Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism." Between June 6, 2013 and January 31, 2014, NBP New York processed seven funds transfers totaling $55,952.14 that were originated by, or destined for, the account of "LC Aircompany Kyrgyztransavia"...
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1) The apparent reason why the filter did not catch the SDN was the lack of spaces in the SDNs name as it showed up on the payment messages "Kyrgyztransavia v. Kyrgyz Trans Avia." Compare Civil Enforcement Information - JPMorgan Chase Bank N.A. (2nd violation, Finding of Violation Component).
OFAC explained that:
On May 31, 2013, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Kyrgyz Trans Avia, an airline headquartered in Bishkek, Kyrgyzstan, pursuant to Executive Order 13224 of September 23, 2001, "Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism." Between June 6, 2013 and January 31, 2014, NBP New York processed seven funds transfers totaling $55,952.14 that were originated by, or destined for, the account of "LC Aircompany Kyrgyztransavia" at...