OFAC has fined the New York Branch of National Bank of Pakistan $28,800 for 7 wire transfers it made to an entity on OFAC’s list of Specially Designated Nationals, totalling $55,952.14. The fine settles the bank’s potential civil liability for the violations.
The transfers were made to Kyrgyz Trans Avia, an airline headquartered in Bishkek, Kyrgyzstan. The bank’s sanctions compliance software, designed to prevent transactions with sanctioned persons, failed to generate an alert warning that the airline was a listed entity and so it processed all 7 transactions in violation of US sanctions. The total base penalty amount for the violations was $64,000, but the bank’s conduct was mitigated by, inter alia, the fact that the violations were the result of a software error and so no one at the bank was aware of the violations.
OFAC’s announcement is here.