On March 11, 2020, Swedbank AB, a major Swedish bank, informed investors of its intention to report to the US Department of the Treasury’s Office of Foreign Assets Control that 586 US-dollar denominated transactions amounting to approximately $4.8 million in the bank’s three Baltic subsidiaries may have violated US sanctions on the Crimea. The suspect transactions were discovered as a result of Swedbank’s anti-money laundering and sanctions investigation, which has been conducted since February 2019 by an outside law firm. The bank noted that most of the transactions took place between 2015 and 2016, and that 508 of the transactions involved payments associated with the operator of a vessel owned and operated in the Crimea.
For more information on Swedbank’s ongoing AML investigation, see here, here and here.