Finding of violation for Nodus International Bank

The Office of Foreign Assets Control (OFAC) has announced it has issued a Finding of Violation to Nodus International Bank, Inc., an international financial entity located in Puerto Rico, for violations of the Venezuelan Sanctions Regulations (VSR) and the Reporting, Penalties and Procedures Regulations (RPPR). The VSR violations related to Nodus’s
voluntary self-disclosure of three unlicensed transactions in which an individual (the “blocked person”) on OFAC’s List of Specially Designated Nationals and Blocked Persons (the “SDN List”) had an interest.

The RPPR violations reflected Nodus’s failure to maintain full and accurate records related to the handling of blocked property and its inaccurate reporting of the blocked property to OFAC. OFAC determined that the appropriate administrative action in this matter was a Finding of Violation in lieu of a civil monetary penalty. This action emphasizes that financial institutions should properly maintain blocked property and records, report such information accurately to OFAC, and obtain a specific license from OFAC in order to deal in blocked property.