Civil Enforcement Information - JPMorgan Chase Bank N.A. (2nd violation, Settlement Agreement Component)

Date issued: Oct. 05 2018

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TURBOFAC Commentary (1181 words)

Notes:

1) See Civil Enforcement Information - JPMorgan Chase Bank N.A. (2nd violation, Finding of Violation Component), where OFAC penalized a bank for not employing a sufficiently sophisticated algorithmic SDN filter.

This is one of two enforcement actions in which OFAC notices to the public a settlement agreement and a separate finding of violation (see also Civil Enforcement Information - Toronto-Dominion Bank and Civil Enforcement Information (FOV) - TD Bank, N.A.). We treat the violations connected to the settlement agreement as an enforcement action separate from the Finding of Violation.

2) It is probably safe to assume that the violations of the WMDPSR are a result of payments made in connection with Iran Air, since i) that appeared...