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OFAC settles with 3M Company and Emigrant Bank

September 21, 2023

OFAC has announced a $9,618,477 settlement with 3M Company. 3M has agreed to settle its potential civil liability for 54 apparent violations of OFAC sanctions on Iran that arose from its subsidiary’s sale of reflective license plate sheeting to an Iranian entity controlled by the Iranian Law Enforcement Forces. Between September 2016 and September 2018, 3M East AG sold 43 orders of this product to a reseller with knowledge that it was destined for a customer in Iran. Additionally, one U.S.-person employee of another 3M subsidiary was substantively involved in these sales. OFAC determined that these apparent violations were egregious and were voluntarily self-disclosed.

OFAC's announcement also reported a settlement with Emigrant Bank (Emigrant). Emigrant agreed to remit $31,867.90 to settle its potential civil liability for apparent violations of sanctions against Iran. For approximately 26 years, Emigrant maintained a Certificate of Deposit account on behalf of two individuals ordinarily resident and located in Iran, for which it processed 30 transactions between June 2017 and March 2021 totaling $91,051.13. Emigrant had actual knowledge of the Iranian address and apparent location of the accountholders during this period. The settlement amount reflects OFAC’s determination that Emigrant’s conduct was non-egregious and voluntarily self-disclosed.

First published on 09/21/2023

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