OFAC announced today that it settled with Clearstream Banking S.A. (“Clearstream”), of Luxembourg, for $151,902,000 for apparent violations of the Iranian Transactions and Sanctions Regulations. According to OFAC, Clearstream maintained an omnibus custodial account for its clients in a US bank, and one of those clients was the Central Bank of Iran (“CBI”). Clearstream had told OFAC in 2008 that it was terminating its business with Iranian clients; but instead of terminating its relationship with CBI, Clearstream just changed the record ownership of the account on its own books from the CBI to a European bank, while CBI’s beneficial ownership remained unchanged. As OFAC describes it, CBI’s interest was merely “buried one level deeper in the custodial chain”. OFAC found this to be an egregious case involving reckless conduct, and one where there had been no voluntary self-disclosure.