CFM Indosuez Wealth — $401,039 OFAC penalty
OFAC published a $401,039 civil penalty against CFM Indosuez Wealth on 09/26/2022. It is the #153 largest action in OFAC’s 1,052-entry enforcement chart and #7 of the 14 actions published that year.
What OFAC said
Enforcement Release: September 26, 2022 OFAC Settles with CFM Indosuez for $401,039 Related to Apparent Violations of Multiple Sanctions Programs CFM Indosuez Wealth ("CFM"), an indirect subsidiary of Credit Agricole Corporate and Investment Bank (CACIB), 1 has agreed to pay $401,039 to settle its potential civil liability for apparent violations of the Cuba, Iran, and Syria sanctions programs.
Quoted verbatim from OFAC’s enforcement release — read the original.
The record
| Entity, as published by OFAC | CFM Indosuez Wealth |
|---|---|
| Penalty / settlement amount | $401,039 |
| Date published by OFAC | 09/26/2022 (OFAC entry b) |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #153 of 1,052 |
| Rank within 2022 | #7 of 14 |
| Share of 2022 penalty total | 0.9% |
| Statutory maximum penalty | $106,853,346 |
| Base penalty | $616,983 |
| Voluntarily self-disclosed | Yes |
| OFAC egregiousness determination | Non-egregious |
| Sanctions programs named in the release | Iran, Cuba, Syria |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $106,853,346. The settled amount of $401,039 is 0.4% of that maximum, which OFAC's Enforcement Guidelines tie to factors including voluntary self-disclosure and whether the conduct was egregious.
Primary source
OFAC enforcement release: 20220926_CFM.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2022 actions
- American Express National Bank — $430,500
- Payward, Inc. (“Kraken”) — $362,158.70
- Banco Popular de Puerto Rico — $255,937.86
- Newmont Corporation — $141,442
- Tango Card, Inc. — $116,048.60
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