Two affiliated Switzerland-based wealth management firms settled OFAC charges for operating U.S. dollar bank accounts on behalf of customers in sanctioned jurisdictions and engaging in U.S. dollar-denominated transactions on behalf of these customers through U.S.-based banks and broker-dealers.

In separate enforcement releases (see here and here), OFAC found that one firm operated accounts for 11 customers in Cuba, Iran and Syria while the other operated accounts for 17 customers located in Cuba, Iran, Syria, Crimea and Sudan. OFAC said that the parent company of the two firms established global sanctions compliance programs however, the firms failed to implement the programs.

OFAC determined that the firms violated provisions of (i) the Cuban Assets Control Regulations, 31 CFR 515, (ii) the Iranian Transactions and Sanctions Regulations, 31 CFR 560, and (iii) the Syrian Sanctions Regulations, 31 CFR 542. OFAC also found that one firm violated provisions of (i) EO 13685 ("Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to the Crimea Region of Ukraine") and (ii) the Sudanese Sanctions Regulations, 31 CFR 538.

To settle the charges, the two firms agreed to remit $401,039 and $720,258, respectively.