Swiss Bank Fined for Cuba, China, Russia Violations

Treasury’s Office of Foreign Assets Control (OFAC) today announced a settlement with EFG International AG, a Switzerland-based global private banking group. EFG has agreed to pay $3,740,442 to settle its potential civil liability for processing 873 securities transactions in apparent violation of the Cuban Asset Control Regulations, the Kingpin Act, and Executive Order 14024. The settlement amount reflects OFAC’s determination that EFG’s apparent violations were voluntarily self-disclosed and were non-egregious.

Between January 2014 and July 2018, EFG subsidiaries located in the Bahamas, Cayman Islands, Luxembourg, Monaco, and Switzerland processed 727 securities-related transactions and funds transfers totaling $29,939,701 through omnibus accounts at U.S. custodians or otherwise involving U.S. market participants, including EFG Miami, on behalf of clients who resided in Cuba or whose beneficial owners were Cuban nationals.

In 2009, EFG’s Singapore branch (“EFG Singapore”) opened an investment account for a
Chinese national that OFAC later designated in 2014 as a Specially Designated Narcotics
Trafficking Kingpin (“SDNTK”).However, for more than four years, EFG Singapore did not notify its U.S. custodian or other U.S. securities firms. 

In 2023, OFAC designated a client of EFG’s Swiss subsidiary, which subsequently caused at least five dividend transactions, worth approximately $1,200, to process through U.S.
securities firms.

The statutory maximum civil monetary penalty applicable in this matter is $276,441,312.
OFAC determined that EFG voluntarily self-disclosed the Apparent Violations and that the
Apparent Violations constitute a non-egregious case.

The settlement amount of $3,740,442, of which $1,000,000 will be suspended pending
satisfactory completion of certain compliance commitments, reflects OFAC’s consideration of
the General Factors under the Enforcement Guidelines.

[OFAC Release]