Latvian Bank Settles Sanctions Violations

Treasury’s Office of Foreign Assets Control said Tuesday it has reached a $3.4 million settlement with Swedbank Latvia to settle its potential civil liability for 386 apparent violations of US sanctions on Crimea.

Throughout 2015 and 2016, a customer of Swedbank Latvia used Swedbank Latvia’s e-banking platform from an internet protocol address in Crimea to send payments to persons in Crimea through correspondent banks, according to OFAC.

The settlement amount reflects OFAC’s determination that Swedbank Latvia’s conduct was non-egregious and not voluntarily self-disclosed.

Specifically, Swedbank Latvia allowed its client to initiate payments from Crimea through the e-banking platform that were ultimately processed by a US correspondent bank. This conduct resulted in the export of financial services to Crimea in violation of US sanctions.

“This case demonstrates the importance of implementing and maintaining effective, risk-based sanctions compliance controls, especially for sophisticated financial institutions operating in proximity to high-risk regions,” OFAC said. “Such controls should account for changes to applicable sanctions and incorporate all relevant available information to conduct responsive and regular screening.”