by John F. Curran, Jacob Gardener, and Christopher Dioguardi
On September 9, Deutsche Bank Trust Company Americas (“Deutsche Bank”) agreed to pay the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) $583,100 to settle potential civil liability for apparent violations of the Ukraine-Related Sanctions Regulations. The settlement, which resolved two types of apparent violations involving two different entities on OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDNs”), underscores the importance for banks to effectively screen transactions and diligently investigate red flags in order to avoid processing payments involving SDNs. It also highlights the value of taking prompt remedial action and fully cooperating with OFAC once an apparent violation is discovered.