January 5th, 2021, La Défense,
UBAF is pleased to confirm that its voluntary self-disclosure (VSD) of apparent violations of US economic sanctions has reached its final conclusion at the end of 2020. UBAF has agreed to pay 8,57 million US$ to settle its potential civil liability.
The VSD was based upon an internal investigation conducted by UBAF, with the assistance of international specialized firms, aimed at identifying any transaction that may have involved (directly or indirectly) U.S.-sanctioned countries, entities or individuals for the period of May 2009-May 2014.
The settlement identified 127 transactions that may have violated U.S. sanctions, the vast majority of which took place in a 5-month period in late 2011 following the imposition of comprehensive U.S. sanctions against Syria.
The bank’s participation in those transactions was based upon an erroneous historical understanding of the scope of U.S. prohibitions on U.S. dollar transactions indirectly involving U.S.-sanctioned parties that clear through the U.S. financial system. The settlement reflects OFAC’s determination that UBAF’s apparent violations were non-egregious and the bank’s voluntary initiation of and cooperation with the investigation, among other factors.
Following UBAF’s initiation of the review leading to this settlement, it adopted a new Financial Security Charter in September 2013 and has continued to make substantial investments in its compliance program, which is regularly updated and improved. The bank remains committed to compliance with all applicable laws following the resolution of this matter.
OFAC’s announcement of the settlement agreement may be found here.
