OFAC reports two settlements for apparent violations

On Thursday, OFAC announced a $9,618,477 settlement with 3M Company. 3M had agreed to settle its potential liability for 54 apparent violations of OFAC's sanctions on Iran arising from its subsidiary's sale of reflective license plate sheeting to an Iranian entity controlled by Iranian law enforcement forces.

OFAC's announcement also reported a settlement with Emigrant Bank, located in New York. Emigrant agreed to remit $31,867.90 to settle its potential civil liability for apparent violations of sanctions against Iran. For approximately 26 years, Emigrant maintained a Certificate of Deposit account on behalf of two individuals ordinarily resident and located in Iran, for which it processed 30 transactions between June 2017 and March 2021 totaling $91,051.13. Emigrant had actual knowledge of the Iranian address and apparent location of the accountholders during this period.

For more information on each of these settlements, see OFAC settles with 3M Company and Emigrant Bank, in the BankersOnline OFAC Updates pages. Additional details on the Emigrant Bank settlement can be found in Emigrant Bank settles with OFAC for apparent violations in BOL's Penalty pages.