Here’s 14 companies that allegedly violated U.S. sanctions in 2022, paid $38M in penalties

Whistleblowers can be rewarded handsomely for exposing corporations that violate U.S. sanctions against doing business with blocked countries, especially those sanctions imposed on Russia for its invasion of Ukraine.

Here’s a look at 14 global companies that agreed to pay civil penalties totaling nearly $38 million during 2022 for violating various U.S. government sanctions.

In by far the largest settlement to-date of 2022, Bittrex Inc. agreed in October to pay a penalty of $24.3 million to settle allegations by the Department of the Treasury related to its apparent violations of multiple sanctions programs. Bittrex is a private company based in Bellevue, Wash., which provides an online virtual currency exchange.

The Treasury Department alleged that the Bittrex violated sanctions between 2014 and 2017 by failing to stop persons apparently located in the Crimea region of Ukraine, Cuba, Iran, Sudan and Syria from using its platform to engage in virtual currency transactions totaling more than $263 million. Bittrex was held liable for 116,421 apparent violations of sanctions programs that prohibit U.S. citizens from engaging in transactions with these countries.

Bittrex had no internal controls in place until October 2017 to screen customers or transactions related to the sanctioned jurisdictions. The company subsequently implemented a number of other remedial measures, including implementing new sanctions screening and blockchain tracing software, conducting additional sanctions compliance training, and hiring additional compliance staff. Once implemented, these remedial measures substantially curtailed the number of apparent violations, the Treasury Department says.

Bittrex’s compliance deficiencies resulted in 13,245 apparent violations of  sanctions involving the Crimea Region of Ukraine; 321 apparent violations of the Cuban Assets Control Regulations; 94,634 apparent violations of the Iranian Transactions and Sanctions Regulations; 222 apparent violations of the now-repealed Sudanese Sanctions Regulations; and 7,999 apparent violations of the Syrian Sanctions Regulations, the Treasury Department said.

In another large sanctions violations settlement, Toll Holdings Limited, an international freight forwarding and logistics company headquartered in Melbourne, Australia, agreed to pay $6.1 million to settle potential civil liability for 2,958 apparent violations of multiple sanctions programs, the Treasury Department announced in April 2022.

The apparent violations occurred when Toll originated or received payments through the U.S. financial system involving sanctioned jurisdictions and persons. These payments were in connection with sea, air, and rail shipments conducted by Toll, its affiliates, or suppliers to, from, or through the Democratic People’s Republic of Korea (DPRK), Iran, or Syria, or the property or interests in property of an entity on the Office of Foreign Assets Control’s (OFAC) list of Specially Designated Nationals and Blocked Persons. The Treasury Department said Toll’s apparent violations were non-egregious and voluntarily self-disclosed, noting that the case “highlights that foreign companies who use the U.S. financial system to engage in commercial activity must take care to avoid transactions with OFACsanctioned countries and persons.”

In another sanctions settlement during the past year, Sojitz (Hong Kong) Limited, a Hong Kong, China-based company that engages in offshore trading and cross-border trade financing, agreed to pay $5.2 million to settle its potential civil liability for apparent violations of the Iranian Transactions and Sanctions Regulations. The apparent violations occurred when Sojitz HK made U.S. dollar payments through U.S. financial institutions for Iranian-origin high density polyethylene resin (HDPE) from its bank in Hong Kong to the HDPE supplier’s banks in Thailand. In doing so, Sojitz HK caused the U.S. financial institutions that processed the funds to engage in and facilitate prohibited financial transactions related to goods of Iranian origin, the Treasury Department said in January 2022.

Here are other sanctions violations settlements announced in 2022:

* Banco Popular de Puerto Rico -- BPPR, a Puerto Rican bank with branches in Puerto Rico and the Virgin Islands, processed 337 transactions totaling $853,126 on behalf of two individuals who were low-level employees of the Government of Venezuela, in apparent violation of U.S. sanctions against Venezuela, the Treasury Department said.

* CA Indosuez (Switzerland) S.A. -- CAIS, a subsidiary of Credit Agricole Corporate and Investment Bank, agreed to pay $720,258 to settle its potential civil liability for apparent violations of the Cuba, Ukraine-related, Iran, Sudan, and Syria sanctions programs, the Treasury Department said.

* American Express National Bank -- Amex, a subsidiary of American Express Company which provides charge and credit card products and travel-related services to consumers and businesses, agreed to pay $430,500 to settle its potential civil liability for 214 apparent violations of OFAC’s Kingpin sanctions. Over the course of two months, Amex processed transactions for an account whose supplemental card holder was designated in connection with illegal drug distribution and money laundering. A combination of human error and sanctions compliance program deficiencies enabled the account to engage in $155,189.42 worth of transactions, the Treasury Department said.

* CFM Indosuez Wealth -- CFM, a subsidiary of Credit Agricole Corporate and Investment Bank, agreed to pay $401,039 to settle its potential civil liability for apparent violations of the Cuba, Iran, and Syria sanctions programs, the Treasury Department said.

*Newmont Corporation – Newmont,a multinational mining firm headquartered in Denver, Colorado, with operations and assets across the globe, agreed to pay $141,442 to settle potential civil liability relating to Newmont subsidiary Newmont Suriname’s purchase of Cuban-origin explosives and explosive accessories from a third-party vendor, in apparent violation of the Cuban Assets Control Regulations, the Treasury Department said.

* Tango Card Inc. -- Tango Card, a Seattle, Washington-based company that supplies and distributes electronic rewards, agreed to pay $116,048 to settle its potential civil liability for apparent violations of multiple U.S. sanctions programs, the Treasury Department said.

* Airbnb Payments Inc. -- Airbnb Payments, a registered money services business headquartered in San Francisco, California, and a wholly owned subsidiary of Airbnb Inc., agreed to pay $91,172 to settle its potential civil liability for apparent violations of sanctions against Cuba administered by the Office of Foreign Assets Control, the Treasury Department said.

*S&P Global Inc. -- S&P Global, a New York-based company that provides business information and financial analytics, agreed to pay $78,750 to settle its potential civil liability for apparent violations of the Ukraine-Related Sanctions Regulations, the Treasury Department said.

* Chisu International Corporation -- Chisu, a Florida-based corporation affiliated with a Suriname-based distributor of explosives and related materials, agreed to pay $45,908 to settle its potential civil liability for apparent violations of the Cuban Assets Control Regulations, the Treasury Department said.

*Nodus International Bank Inc.  -- Nodus, an international financial entity located in Puerto Rico, settled for alleged violations of the Venezuelan Sanctions Regulations, the Treasury Department said.

* MidFirst Bank – MidFirst allegedly violated the Weapons of Mass Destruction Proliferators Sanctions Regulations. The violations related to MidFirst’s maintaining accounts for and processing of 34 payments on behalf of two individuals added to OFAC’s List of Specially Designated Nationals and Blocked Persons, the Treasury Department said.

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