First Bank processed 34 outgoing payments, totaling $991,246, through U.S.As a result, First Bank commenced a five-year lookback in March 2019 and voluntarily self-disclosed the results to OFAC.Īccording to OFAC, the following payments violated sections 560.203, 560.204, and 560.215 of the Iranian Transactions and Sanctions Regulations, 31 CFR part 560, and sections 542.205 and 542.207 of the Syrian Sanctions Regulations, 31 CFR part 542. dollar transaction that First Bank had processed for a shipment of timber from Romania to Syria. In 2019, First Bank’s regulator, the National Bank of Romania, flagged a U.S. companies should continue to conduct due diligence to determine whether a transaction involves a U.S. financial system or within the United States. sanctions regulations applicable to transactions processed through the U.S. This settlement agreement emphasizes the broad scope of U.S. In 2018, after JC Flowers acquired a majority ownership interest in First Bank, First Bank processed Euro-denominated payments for persons located in Iran. banks on behalf of parties located in Iran and Syria. More specifically, First Bank processed 98 commercial transactions totaling $3,589,189 through U.S. According to a press release, the companies agreed to pay $862,318 to settle potential civil liability related to First Bank’s processing of transactions in apparent violation of OFAC’s Iran and Syria sanctions programs. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) entered a settlement agreement with First Bank SA (“First Bank”), located in Romania, and its U.S.