3M and Emigrant Bank settle apparent violations of Iran sanctions

US multinational 3M and New York-based Emigrant Bank have separately settled with the Office of Financial Assets Control (‘OFAC’) for potential civil liability related to apparent violations of sanctions on Iran.

3M agreed to a $9,618,477 settlement ‘to settle its potential civil liability for 54 apparent violations of OFAC sanctions on Iran that arose from its subsidiary’s sale of reflective license plate sheeting to an Iranian entity controlled by the Iranian Law Enforcement Forces,’ the Treasury Department said in a media statement, 21 September.

It explained that between September 2016 and September 2018 its Swiss subsidiary, 3M East AG, sold 43 orders of this product to a reseller with knowledge that it was destined for a customer in Iran, and that ‘one U.S.-person employee of another 3M subsidiary was substantively involved in these sales.’

OFAC said it had ‘determined that these apparent violations were egregious and were voluntarily self-disclosed.’

Separately, OFAC also announced a settlement with Emigrant Bank, which agreed to remit $31,867.90 to settle its potential civil liability.

‘For approximately 26 years, Emigrant maintained a Certificate of Deposit account on behalf of two individuals ordinarily resident and located in Iran, for which it processed 30 transactions between June 2017 and March 2021 totaling $91,051.13,’ OFAC said.

‘Emigrant had actual knowledge of the Iranian address and apparent location of the accountholders during this period. The settlement amount reflects OFAC’s determination that Emigrant’s conduct was non-egregious and voluntarily self-disclosed,’ OFAC said.

https://content.govdelivery.com/accounts/USTREAS/bulletins/371b038