- Cited civil liability for 87 apparent violations of Cuban Assets Control Regulations.
Iranian Transactions and Sanctions Regulations; and WMD Sanctions Regulations.
- Transactions were net settlement payments, and a very small portion appears to
have been attributable to interests of airlines that were at times, on the SDN list.
- Or located in countries, subject to the sanctions programs administered by OFAC.
- The violations do not include transactions, exempt from prohibitions of the IEEPA.
- Violations included transactions, e.g. airline freight charges, that are not exempt.
- JPMC voluntarily self-disclosed violations, which constituted a non-egregious case.
- OFAC issued finding of violation re sanctions of the Foreign Narcotics Kingpin rule.
- OFAC found Syrian sanctions violations on behalf of six customers on the SDN list.
- JPMC voluntarily self-disclosed the violations, and constituted non-egregious case.