OFAC issued a "Finding of Violation" against State Street Bank and Trust Co. ("SSBT") with respect to Iranian Transactions and Sanctions Regulations. There is no monetary penalty associated with a Finding of Violation.
OFAC stated that, between 2012 and 2015, SSBT acted as a trustee for a customer's employee retirement plan. According to OFAC, SSBT processed at least 45 pension payments totaling approximately $11,000 to a participant in a retirement plan who was a U.S. citizen with a U.S. bank account, but who also was an Iranian resident. OFAC alleged that SSBT appears to have known it was sending payments to an account for the benefit of a person in Iran because (i) the bank's systems indicated that the beneficiary's address was in Iran and (ii) the bank's sanctions screening software produced an alert, due to the address in Iran, for each of the 45 payments.
According to OFAC, the matter was self-disclosed, the payments may not actually have been transferred to Iran, and it is possible that the fund transfers could have become licensed. OFAC imposed no monetary penalty with respect to the Finding of Violation.
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