Barclays Bank Settles Allegations of Multiple Sanctions Programs for $176 Million

On August 18, 2010, Office of Foreign Assets Control (OFAC) announced that Barclays Bank PLC (Barclays) has agreed to settle allegations of violating the Sudanese Sanctions Regulations, the Iranian Transactions Regulations, the Burmese Sanctions Regulations, and the Cuban Assets Control Regulations, promulgated under either the International Emergency Economic Powers Act (IEEPA) or the Trading With the Enemy Act (TWEA). The settlement with OFAC is part of a global settlement among Barclays, OFAC, the U.S. Department of Justice, and the New York Country District Attorney's Office.

Barclays agreed to settle with OFAC the alleged violations for $176 million. The obligation was deemed satisfied by Barclay's payment of $298 million to the Department of Justice (DOJ) and the New York County District Attorney's Office.  

OFAC stated that, "Barclay's violations arose out of practices designed to circumvent filters at U.S. banks installed to detect transactions in violation of OFAC regulations. This was done using cover payments to avoid referencing parties targeted by U.S. sanctions and omitting or removing information in payment messages in order to conceal the identities of U.S. sanctions targets - most notably Sudan - in electronic funds transfer instructions executed through the United States. In addition, Barclays sometimes processed payments involving sanctioned persons through a Barclays sundry account, making it appear as though Barclays was the remitting bank." 

Based on OFAC's analysis of information provided by Barclays, from August 2002 through September 2006 Barclays routed at least 1,285 electronic funds transfers, with an aggregate value of approximately $112.7 million, through Barclays New York and third-party banks located in the United States.  

Barclays has terminated the practices leading to violations of OFAC regulations and has put in place policies and procedures that are designed to minimize the risk of the recurrence of similar conduct in the future. The bank voluntarily self-disclosed the apparent violations and has cooperated fully with OFAC.