September 9, 2020

Deutsche Bank Trust Company Americas settles apparent Ukraine-related sanctions violations

The Office of Foreign Assets Control of the US Department of the Treasury has announced the settlement of apparent Ukraine-related sanctions violations with Deutsche Bank Trust Company Americas (DBTCA), a New York-incorporated subsidiary of Deutsche Bank operating as a bank in the United States.  According to OFAC, DBTCA:

  1. processed a large payment in August 2015 related to over $28 million of fuel oil purchases involving IPP Oil Products (Cyprus) Limited, a Cypriot company designated by OFAC pursuant to Executive Order 13661, and failed to conduct sufficient due diligence to determine the interest of the designated entity, and;
  2. processed 61 payments destined for Open Joint Stock Company Krasnodar Regional Investment Bank, a Crimean financial institution designated pursuant to Executive Order 13685 in December 2015; because it had failed to include the SWIFT number of the designated institution in the DBTCA sanctions screening tool.

OFAC determined that DBTCA had not voluntarily disclosed the incidents to OFAC, but that neither case was egregious. To resolve OFAC’s investigation into these apparent violations, DBTC agreed to pay $157,500 for the IPP payment, and $425,600 for the inadequately screened payment processing transactions for Krasnodar Bank.  In addition, DBTCA has agreed provide sanctions training programs for its employees, to maintain robust compliance procedures, and to ensure that its risk assessments are conducted in a manner adequately designed to address sanctions risks.

OFAC press release | Enforcement Release