The New York branch of the National Bank of Pakistan (“NBP New York”) agreed in mid-June to a $28,800 settlement with OFAC for seven apparent violations of the Global Terrorism Sanctions Regulations (GTSR). Between June 2013 and January 2014, NBP New York processed seven fund transfers to or from the account of LC Aircompany Kyrgyztransavia, an entity on the SDN List. Although NBP New York employed interdiction software, the software failed to flag the transactions.

OFAC found that NBP New York did not voluntarily disclose the apparent violations. The settlement, a reduction from the base penalty of $64,000, reflects, among other factors, OFAC’s determination that NBP New York’s management did not have knowledge of the issue leading to the apparent violations (because the interdiction software failed to identify the SDN) and that the bank took remedial action, including enhancement of its interdiction software.

OFAC commented that its enforcement action highlights the risk that foreign financial institutions with U.S. locations face when they have accountholders subject to OFAC sanctions.

Find out more by reading OFAC’s enforcement notice.