OFAC REACHES $7.4 MILLION DOLLAR SETTLEMENT WITH STATE STREET BANK AND TRUST COMPANY FOR VIOLATIONS OF UKRAINE/RUSSIA SANCTIONS
August 12, 2024
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On July 26, 2024, OFAC announced that it had reached a $7,452,501 settlement with State Street Bank and Trust Company for apparent violations of OFAC’s Ukraine-/Russia-Related Sanctions Regulations (“Sanctions”.) The Massachusetts based company agreed to the settlement on behalf of itself and its subsidiary Charles River Systems, Inc. (“Charles River”) because of alleged misconduct related to invoices that were erroneously redated or reissued. The thirty-eight (38) violations occurred between 2016 and 2020 and totaled $1,270,456. Notably, Charles River had maintained relationships with subsidiaries owned by Russian financial institutions identified by OFAC to be subject to it’s Directive 1 which prohibits holding certain debts beyond a certain period. Charles River is alleged to have been aware that it had invoices from Directive 1 identified entities that had exceeded the maximum holding period. In order to mask this, Charles River is alleged to have changed and reissued invoices to make them appear more recent. OFAC found that Charles River’s violations were egregious which it noted that the institution had failed to self-disclose.
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