Puerto Rico-Based Financial Entity Slapped with “Finding of Violation” for Violating US Sanctions Against Venezuela

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The United States Treasury Department’s Office of Foreign Assets Control (OFAC) has issued a “finding of violation” against an international financial entity based in Puerto Rico, citing violations of sanctions regulations and reporting requirements related to Venezuela.

Summary of the Violations

• The bank voluntarily self-disclosed three unlicensed transactions involving an individual listed on OFAC’s Specially Designated Nationals and Blocked Persons (SDN) list.
• The bank failed to maintain accurate records of blocked property.
• The bank inaccurately reported this information to OFAC.

Administrative Action Taken

Despite these violations, OFAC determined that a “finding of violation” was the appropriate administrative action instead of imposing a civil monetary penalty.

Takeaways and Next Steps

• To navigate US sanctions regulations and reporting requirements, contact KPMG’s Trade & Customs services team for more information.
• Understanding the importance of accurate record-keeping and timely reporting in compliance with OFAC regulations.