Lloyds TSB Bank, plc, located in London has agreed to pay a settlement of $217 million to settle allegations of violations of the Iranian Transactions Regulations, the Sudanese Sanctions Regulations, and the Libyan Sanctions Regulations. Apparently the bank had a policy to deliberately change and delete information in wire transfers regarding Iran, Sudan, and Libya to ensure that third-party US banks would not discover the sanctioned parties. Between June 2003 and August 2006, the bank routed close to 4,200 electronic funds transfers with a total value of $36,988,457 through US banks.

The bank cooperated with OFAC’s investigation but did not voluntarily disclose the violations. Lloyds hired an independent consulting firm to review all incoming and outgoing payment messages and monthly account statements for accounts in question during their review period and provided all findings to OFAC. Lloyds has also agreed to have its Internal Audit Department conduct annual audits for the next 2 years and provide these reports to a qualified independent auditor to certify the findings.

Lloyd’s obligation to pay the $217 million fine has been deemed satisfied by their recent settlement payment of $350 million made in early 2009.

Settlement: http://www.treas.gov/offices/enforcement/ofac/civpen/penalties/12222009.pdf

This entry was posted on Wednesday, February 17th, 2010 at 7:59 pm by Danielle McClellan and is filed under Finance & Banking, Iran, Libya, OFAC, Sanctions, Sudan, Treasury Dept, Violations & Fines. You can follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.