The Office of Foreign Assets Control settled its first case of 2024, and it’s a significant one. According to reports, EFG International AG, a private global banking group based out of Switzerland, has agreed to pay over $3.74 million for violations of multiple sanctions programs.

The OFAC accused EFG of committing at least 727 securities transactions for customers located in Cuba in violation of current sanctions. On top of that, they reportedly directed at least 141 securities-related transactions for individuals that were specifically blocked from performing them due to the Kingpin Act. Most recently, they were accused of making five different dividend payments for a person who was blocked under OFAC’s Russia Sanctions program.

The transactions with Cuban nationals or residents occurred between 2014 and 2018. EFG’s clients were allegedly based out of Panama but actually owned by Cuban nationals and residents. In 2009, EFG’s branch located in Singapore reportedly opened an account for an individual who was listed as a “Specially Designated Narcotics Trafficking Kingpin”. The Chinese national then used his account to direct the 141 transactions that violated U.S. sanctions. Finally, in 2023, EFG conducted illegal dividend payment transactions as a result of clerical errors.

After investigating what happened, OFAC determined that the EFG was negligent because they failed to exercise due care by screening potential clients and ensuring they were not in violation of OFAC sanctions. OFAC found that EFG was very cooperative during the investigation.

While $3.74 million dollars seems like a very significant sum, the OFAC was lenient in settling the issue with EFG since they voluntarily disclosed the violations. On top of that, the agency ruled that the violations weren’t egregious.

Have You Potentially Violated OFAC Sanctions?

Are you doing your due diligence to ensure that you’re not in violation of OFAC sanctions? You need to ensure that you’re not doing business with any individuals or entities that have been blacklisted through sanctions. If you are found doing so, then you could face very serious consequences.

Doing business with a blacklisted individual or entity is considered a very serious threat to national security and foreign relations. If you’re charged with violating sanctions and get convicted, then you could sentenced to up to 30 years in prison. You could also face very serious monetary fines that could reach millions of dollars, like in the case above.

If you have recently realized that you violated OFAC sanctions in the past, then it’s best to address the situation, like the company did above. Through voluntary disclosure, companies are more likely to experience some degree of leniency as a result of their actions.

Before you make any move, though, you should discuss your situation with an international attorney who has experience handling OFAC sanctions violation cases. Here at Bukh Global, we know our team can help you navigate the complexities of your situation.

Are you ready to get started? Schedule a call with our attorneys now to discuss your situation in more detail.