OFAC has reached a settlement of $4m with British Arab Commercial Bank (BACB), a commercial bank based in London, UK, with “no offices, business or presence under the US jurisdiction”.

BACB processed 72 bulk funding payments totalling approximately $190m on behalf of 7 Sudanese financial institutions, including the Central Bank of Sudan, between September 2010 and August 2014.

In apparent violations of the Sudanese Sanctions Regulations, BCAB maintained a USD nostro account (an account held by a UK bank in foreign currency in a foreign bank), which was held outside the US, but the funding for that account was routed through US. That nostro account was then used to facilitate transactions (processed outside of . . .

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