The Office for Foreign Assets Control (OFAC) recently announced a $4 million USD settlement with the British Arab Commercial Bank (BACB), in relation to BACB’s alleged violations of OFAC’s sanctions on Sudan.

The $4 million amount is significantly down from the base penalty of $381.4 million dollars that BACB could have been subject to for their multiple alleged Sudan-related OFAC violations between 2010 and 2014. The lower penalty is a result of BACB’s cooperation with the investigation, and their move to have a compliance program in place to help avoid any future similar violations. All of these have been cited by OFAC as mitigating factors, and which consequently helped bring down the penalty for the bank.

OFAC alleges that BACB set up and processed U.S. $190.7 million U.S. dollars’ worth of transactions for Sudanese clients in this period, with several of them routed through U.S. financial institutions.

This case, like other similar ones, highlights the importance of having a strong compliance process and system in place, as well as the importance of voluntary self-disclosure to OFAC in the event of suspected violations.