The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $2,485,890 settlement with Barclays Bank Plc (Barclays). Barclays agreed to settle its potential civil liability for 159 apparent violations of the Zimbabwe Sanctions Regulations, 31 C.F.R. Part 541. From July 2008 to September 2013, Barclays processed 159 transactions totaling $3,375,617 to or through financial institutions located in the United States – including Barclays’ New York branch – for or on behalf of corporate customers of Barclays Bank of Zimbabwe Limited that were owned 50 percent or more, directly or indirectly, by a person identified on OFAC’s List of Specially Designated Nationals and Blocked Persons.
This enforcement action highlights the importance for institutions with operations in countries with a significant presence of persons (individuals and entities) on the SDN List to take appropriate measures to ensure compliance with U.S. economic sanctions laws when processing transactions on behalf of their customers to, through, or within the United States.