On 27 January 2014, Bank of Moscow, a financial institution based in the Russian Federation, agreed to remit $9,492,525 to settle with the US Treasury Department’s Office of Foreign Asset Control (“OFAC”) for apparent violations of the US sanctions against proliferators of weapons of mass destruction. OFAC alleged that the apparent violations occurred as a result of 69 fund transfers in 2008 and 2009 totalling more than $41 million for or on behalf of Bank Melli Iran ZAO, Moscow, Russia (“BMI Russia”), a Russian affiliate of Iran’s Bank Melli designated as a WMD proliferator under Executive Order 13382.

According to OFAC, the SWIFT messages sent by Bank of Moscow to US financial institutions failed to properly identify BMI Russia, and as a result, the US banks processed the fund transfers straight through without manual intervention. OFAC found Bank of Moscow’s alleged violations to constitute a non-egregious case and noted that, although

Bank of Moscow did not voluntarily self-disclose and failed to exercise an appropriate degree of caution or care in avoiding the conduct that led to the alleged violations, the bank cooperated with OFAC’s investigation by agreeing to toll the statute of limitations and took remedial action to improve compliance with US sanctions laws and regulations.

OFAC enforcement announcement