OFAC Fine JPM Cuba Sanctions

On Oct. 5, OFAC fined JPMC $5.2mn for sanctioned activities.

  • Cited civil liability for 87 apparent violations of Cuban Assets Control Regulations.
    Iranian Transactions and Sanctions Regulations; and WMD Sanctions Regulations.

Cuban Transactions

  • 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.

Other violations

  • 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.