UBS AG settled potential charges that from January 2008 to January 2013, it processed 222 transactions related to securities held in custody in the United States for an individual customer of UBS in Switzerland that was designated by the US Department of the Treasury’s Office of Foreign Asset Controls in 2001 as a person with whom business must not be conducted because he was associated with terrorism. To settle this matter UBS agreed to pay OFAC a fine of US $1.7 million. According to OFAC, UBS opened accounts for the client in 1993 and 1994. In 2001, the client was included on OFACS’s List of Specially Designated Nationals and Blocked Persons. Other jurisdictions, including Switzerland, the United Kingdom, the European Union and the United Nations, also imposed sanctions against the client at approximately the same time. In response, UBS apparently placed blocks on the client’s accounts to prevent him from withdrawing or transferring any funds or assets outside the bank. However, the bank allegedly continued to engage in investment-related activity for the client. Such activity was not detected by the bank’s OFAC controls because securities-related transactions were regarded as internal transactions and thus did not generate any alerts. The activity was only discovered in 2012, after the client was removed from the Swiss sanctions list. According to OFAC, “[t]his enforcement action highlights the importance of institutions taking appropriate measures to ensure compliance with all applicable sanctions when they have operations or otherwise conduct business in multiple jurisdictions that have implemented sanctions against particular persons (individuals or entities) or countries. This action should also raise awareness regarding the sanctions obligations for foreign financial institutions — including those that purchase, sell, transfer, or otherwise transact in U.S. securities — that process transactions to or through the United States.”