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ENFORCEMENT INFORMATION FOR OCTOBER 5, 2018
JPMorgan Chase Bank, N.A. Settles Potential Civil Liability for Apparent Violations of Multiple Sanctions Programs: JPMorgan Chase Bank, N.A. (JPMC) has agreed to remit $5,263,171 to settle its potential civil liability for apparent violations involving the processing of 87 net settlement payments with a total value of $1,022,408,149, of which approximately $1,500,000 (0.14%) appears to have been attributable to interests of sanctions-targeted parties, and which therefore appear to have violated one or more of the following sanctions programs administered by OFAC: the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (CACR); the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR); and the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. Part 544 (WMDPSR).
OFAC has determined that JPMC voluntarily self-disclosed the apparent violations, and that the apparent violations constitute a non-egregious case. The total base...
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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...