Treasury Department’s OFAC Issues Finding of Violation to Puerto Rico-Based Financial Entity for Venezuelan Sanctions and Reporting Violations

The Office of Foreign Assets Control (OFAC), a part of the US Treasury Department, has issued a finding of violation against an international financial entity based in Puerto Rico. The entity was found to have violated both the Venezuelan sanctions regulations and the reporting, penalties, and procedures regulations.

Violations

According to OFAC’s release, the bank voluntarily self-disclosed three unlicensed transactions involving an individual on OFAC’s list of specially designated nationals and blocked persons (SDN List). Additionally, the bank failed to maintain full and accurate records related to the handling of blocked property and inaccurately reported the blocked property to OFAC.

Consequences

Instead of imposing a civil monetary penalty, OFAC determined that the appropriate administrative action was a finding of violation. This move serves as a warning to other international financial entities operating in Puerto Rico and around the world that non-compliance with US sanctions regulations will be met with swift action.

Compliance Tips

To ensure compliance with US sanctions regulations, consider the following tips:

• Maintain accurate records related to transactions involving blocked property
• Report all transactions involving blocked property to OFAC
• Conduct thorough due diligence on customers and transactions before engaging in any activity

Get Expert Advice

For more information on how to ensure compliance with US sanctions regulations, contact KPMG’s Trade & Customs services team at:

• dzuvich@kpmg.com
• jlmcloughlin@kpmg.com
• asiciliano@kpmg.com
• sbrotherton@kpmg.com