The U.S. Department of the Treasury’s OFAC Announces Settlements with 3M Company and Emigrant Bank for Sanctions Violations

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced two settlements:

1. 3M Company Settlement: 3M Company has agreed to a settlement of $9,618,477 to resolve its potential civil liability for 54 apparent violations of OFAC sanctions related to Iran. These violations arose from its subsidiary, 3M East AG, selling 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 intended 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 but were voluntarily self-disclosed by 3M. For more details, please refer to the provided web notice and settlement agreement.
2. Emigrant Bank Settlement: Emigrant Bank has agreed to remit $31,867.90 to settle its potential civil liability for apparent violations of sanctions against Iran. Emigrant maintained a Certificate of Deposit account for two individuals ordinarily residing in Iran for approximately 26 years. During this period, Emigrant processed 30 transactions totaling $91,051.13. Emigrant had actual knowledge of the Iranian address and apparent location of the accountholders. The settlement amount reflects OFAC’s determination that Emigrant’s conduct was non-egregious and was voluntarily self-disclosed. For more details, please refer to the provided web notice.