The United States Treasury Department has announced that Deutsche Bank will pay $583,100 in settlements for “apparent violations of Ukraine-related sanctions regulations.”
Deutsche Bank Trust Company Americas (DBTCA) agreed to pay $157,500 for processing a large payment related to a series of purchases of fuel oil that involved a property interest of a designated oil company in Cyprus.
The bank at the time had reason to know of the designated oil company’s interest but “did not conduct sufficient due diligence to determine whether the interest in the payment had been extinguished”, an enforcement notice published by the Treasury Departments Office of Assets of Foreign Control (OFAC) said.
DBTCA has committed to review the circumstances of the apparent violation and perform any changes to the bank’s internal procedures.
OFAC said: “Financial institutions should take a risk-based approach to sanctions compliance. In this instance, DBTCA was aware that it would be receiving a large funds transfer related to a series of transactions that at some point involved a specially designated person (SDN).”
“OFAC would have expected DBTCA take steps to corroborate independently the representations it received in order to assure itself that IPP did not have a present, future, or contingent interest in the payment it was requested to process, regardless of its time sensitivity.”
DBTCA also agreed to remit $425,600 for processing payments destined for accounts at a designated financial institution.
It failed to stop 61 payments because it had not included in its sanctions screening tool the institution’s Society for Worldwide Interbank Financial Telecommunication (SWIFT) Business Identifier Code (BIC). DBTCA promptly implemented changes to its procedures for adding BICs to its screening tool.
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