Evelyn Sheehan Explains Recent OFAC Enforcement Actions in Global Trade Review
January 7, 2021
Publication: Global Trade Review
A French bank’s settlement with the U.S. Office of Foreign Assets Control (OFAC) over sanctions breaches is “a good example of ‘bread and butter’ sanctions enforcement by OFAC,” Kobre & Kim’s Evelyn Sheehan told Global Trade Review in her analysis of the case.
The bank, Union de Banques Arabes et Françaises, was found to have processed dollar-denominated transactions on behalf of Syrian financial institutions in violation of U.S. sanctions and was fined US $8.5 million. This follows another OFAC enforcement action against Saudi-based National Commercial Bank for similar violations.
Although a demonstration of the dramatic reach of U.S. sanctions, these enforcement actions are “not particularly remarkable from a legal perspective,” Sheehan explained. “OFAC has signaled consistently through statements and enforcement actions that transactions like those at issue that ‘transited through the U.S. financial system’ – typically through U.S. dollar denominated correspondent bank accounts – are subject to U.S. sanctions,” she elaborated.