Russian Bank Settles Allegations of Weapons of Mass Destruction Proliferators Sanctions Regulations

On January 27, 2014, Joint-Stock Commercial Bank “Bank of Moscow” (Bank of Moscow), of Moscow, Russian Federation, has agreed to remit $9,492,525 to settle potential civil liability for 69 alleged violations of Executive Order 13382 of June 28, 2005 (E.O. 13382), and the Weapons of Mass Destruction Proliferators Sanctions Regulations.  

On October 25, 2007, OFAC designated Bank Melli Iran ZAO, Moscow, Russia (BMI Russia) pursuant to E.O. 13382.  From January 2008 to July 2009, Bank of Moscow sent 69 funds transfers totaling over $41 million for or on behalf of BMI Russia that were processed to or through the United States.  None of the Society for Worldwide Interbank Financial Telecommunication (SWIFT) payment messages sent by Bank of Moscow in connection with these funds transfers included specific references to “Melli,” “Iran,” or BMI Russia’s SWIFT Business Identifier Code, but instead identified the bank through abbreviations such as “BMICJSCMOSCOWRUSSIA” (a reference to Bank Melli Iran Closed Joint Stock Company Moscow Russia) or “BMI CJSC.”  U.S. financial institutions processed all 69 of the funds transfers straight through without manual intervention.  

Bank of Moscow did not voluntarily self-disclose the alleged violations and the alleged violations constitute a non-egregious case.  The total base penalty amount for the alleged violations was $14,063,000.