On 20 October 2015, OFAC announced that Crédit Agricole Corporate Investment Bank (“CACIB”) had agreed to pay a combined settlement of $787,300,000 to US federal and state agencies for improperly processing wire transfers through the United States. The settlement includes a $329,593,585 payment under a settlement agreement with OFAC and additional penalties and forfeitures under deferred-prosecution agreements announced by the U.S. Department of Justice and the New York County District Attorney’s Office and consent orders announced by the Board of Governors of the Federal Reserve System and the New York State Department of Financial Services.
According to OFAC’s allegations, from 2003 to 2008, CACIB knowingly used SWIFT “cover payment” messages and other practices to process wire transfers through banks in the United States while concealing the identity of the actual senders or beneficiaries of the transfers. As a result, 4,297 payments that apparently should have been blocked or rejected were processed through the US banking system. OFAC found that the apparent violations were not voluntarily self-disclosed and constituted an “egregious case”.