Alerts

OFAC Continues To Focus on Cases Involving Stripping Material Information from Financial Transactions

October 1, 2009

On Aug. 24, 2009, the Office of Foreign Assets Control (“OFAC”) released enforcement information advising that Australia and New Zealand Bank Group, Ltd. (“ANZ Bank”), based in Melbourne, Australia, paid $5.75 million to settle allegations that, from 2004 to 2006, it violated the Sudanese Sanctions Regulations and Cuban Assets Control Regulations. Specifically, OFAC alleged that ANZ Bank removed, or “stripped,” references to Sudan and the names of entities subject to the Sudanese and Cuban sanctions programs from SWIFT messages before forwarding the messages to U.S. correspondent banks. By removing this information, OFAC claimed, ANZ Bank concealed the identity of the sanctions targets and impeded U.S. banks from identifying the prohibited transactions.