Tokyo Bank Paying $8.6 Million as as Result of OFAC Charges
The Bank of Tokyo-Mitsubishi UFJ agreed to pay $8,571,634 to settle civil liability for apparent violations of the Burmese Sanctions Regulations, the Iranian Transactions Regulations, the Sudanese Sanctions Regulations, and the Cuban Assets Control Regulations between April 3, 2006, and March 16, 2007, said the Treasury Department's Office of Foreign Assets Control.
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It said BTMU's Tokyo operations engaged in practices designed to conceal the involvement of countries or persons subject to U.S. sanctions in transactions that BTMU processed through financial institutions in the U.S. It said BTMU employees systematically deleted or omitted from payment messages any information referencing U.S. sanctions targets that would cause the funds to be blocked or rejected, prior to sending the transactions through the U.S. BTMU processed at least 97 funds transfers, with an aggregate value of about $5,898,943, through BTMU's New York branch or other banks in the U.S., OFAC said.
In 2007, BTMU's senior management learned of these practices, commenced an internal review of historical transaction data, and initiated a voluntary self-disclosure to OFAC. The settlement amount reflects OFAC's view that BTMU's conduct displayed reckless disregard for U.S. sanctions, that officials knew or had reason to know that employees manipulated payment instructions, that BTMU's conduct conferred a substantial economic benefit to targets of OFAC sanctions, and that BTMU has undertaken significant remediation to improve its OFAC compliance policies and procedures and substantially cooperated with OFAC's investigation.