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Cooperation, Openness with OFAC Can Help Limit Pain of Penalties

By Matt Squire

National Australia Bank Ltd.'s remittance of $100,000 to the U.S. Treasury's Office of Foreign Assets Control to settle charges that it violated U.S. economic sanctions against Cuba and other countries marked the largest settlement with OFAC by a financial institution this year. But the penalty could have been much larger. OFAC said in a Sept. 7 enforcement action report that it reduced National Australia's penalty by nearly 90 percent because the bank had voluntarily disclosed violations and upgraded its compliance policies. The case is a prime illustration of how financial institutions can significantly reduce fines for sanctions violations if they...

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