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December 17, 2013

HSBC Bank to Pay OFAC $32,400

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has announced the HSBC Bank USA, N.A. (HBUS) has agreed to pay $32,400 to settle potential civil liability for three apparent violations of the Global Terrorism Sanctions Regulations.

OFAC said that HBUS voluntarily self-disclosed the apparent violations and that those apparent violations constituted a non-egregious case, nor were they the result of willful or reckless conduct. OFAC's description of the transactions involved suggests that there was a week spot in HBUS's OFAC interdiction software and that an HBUS compliance officer erred in not screening names provided in a SWIFT message. As a consequence, an allegedly violative payment was allowed. Further, it appears that HBUS OFAC Compliance later failed to recognize information suggesting that future payments involving the same OFAC-designated parties were likely to occur. The second and third apparent violations occurred within the following four months.

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