The Bank of Moscow has agreed to pay $9,492,525 to settle allegations that it handled transfers for Bank Melli Iran ZAO, Moscow, Russia (BMI), violating US sanctions against BMI.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) has issued an enforcement notice containing findings that the Bank of Moscow sent 69 funds transfers totalling $41,306,113 for or on behalf of BMI that were processed to or through the US. None of the payment messages included specific references to Melli or Iran but instead identified BMI through abbreviations.

The OFAC found that the Bank of Moscow did not have adequate compliance policies or procedures in place to prevent breaches of sanctions at the time, although the remedial action taken since was considered a mitigating factor.

A copy of the OFAC enforcement notice is available. http://www.treasury.gov/resource-center/sanctions/CivPen/Documents/20140127_moscow.pdf