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Episode 294 — Catch Up on OFAC Enforcement Actions: 3M and Emigrant Bank

The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare institutions. Another federal agency, OFAC, yesterday announced that it had settled with 3M for $9.6 million over alleged violations of the Iranian Transactions and Sanctions Regulations.

In another OFAC enforcement action, Emigrant Bank (“Emigrant”), a U.S.-based financial institution that bills itself as the oldest bank in New York City, agreed to pay $31,867 to resolve 30 potential violations of the Iran Sanctions Program. The violations all relate to a single CD account (“the account”) that Emigrant maintained for two Iranian residents from 1995 until it closed the account in 2021.

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