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OFAC Settles Case with Moscow Bank Over Iran Financial Transfers

The Treasury Department’s Office of Foreign Assets Control (OFAC) settled a potential civil liability case on Jan. 27 with Joint-Stock Commercial Bank “Bank of Moscow” for $9,492,525 over alleged violations of the Weapons of Mass Destruction Proliferators Sanctions Regulations and…

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Executive Order 13382. OFAC said Bank of Moscow committed 69 violations of the executive order (here) aimed at freezing the assets of weapons proliferators, and did not voluntarily self-disclose the alleged violations. OFAC determined, however, the alleged violations constitute a non-egregious case. From 2008 to 2009, Bank of Moscow allegedly transferred funds to or through the U.S. on behalf of an Iran-affiliated financial institution.