OFAC Issues 'Finding Of Violation' Against Bank For Sanctions Violations

OFAC issued a "Finding of Violation" against State Street Bank and Trust Co. ("SSBT") with respect to Iranian Transactions and Sanctions Regulations. There is no monetary penalty associated with a Finding of Violation.

OFAC stated that, between 2012 and 2015, SSBT acted as a trustee for a customer's employee retirement plan. According to OFAC, SSBT processed at least 45 pension payments totaling approximately $11,000 to a participant in a retirement plan who was a U.S. citizen with a U.S. bank account, but who also was an Iranian resident. OFAC alleged that SSBT appears to have known it was sending payments to an account for the benefit of a person in Iran because (i) the bank's systems indicated that the beneficiary's address was in Iran and (ii)...