Compliance
Crédit Agricole Units Settle With US Over Sanctions Violations

Subsidiaries of Crédit Agricole that operated from Switzerland and Monaco have agreed to remit money to the US for violating sanctions against a number of countries, including controls connected to Ukraine. The violations go back almost a decade.
CA Indosuez Switzerland (CAIS) has agreed to remit $720,258 to
settle a potential civil liability for violating US sanctions
against Cuba, Sudan, Syria and the Crimea. In a separate matter,
another Crédit Agricole
business unit agreed to remit $401,039 for sanctions
violations.
The US Department of the Treasury’s Office of Foreign Assets
Control yesterday announced a settlement with the group.
CAIS is an indirect subsidiary of Credit Agricole Corporate
and Investment Bank, which is in Switzerland and specializes in
wealth management and corporate and investment banking.
CAIS operated dollar banking and securities accounts on behalf of
17 individual customers located in sanctioned jurisdictions,
including the Crimea region of Ukraine, and conducted dollar
business for these customers through the US financial system,
including through US correspondent banks and US registered
brokers or dealers in securities, the Treasury said.
Separately, OFAC today announced a settlement with CFM Indosuez
Wealth, an indirect subsidiary of Credit Agricole Corporate and
Investment Bank located in Monaco that specializes in wealth
management and corporate and investment banking.
CFM agreed to remit $401,039 to settle its potential civil
liability for apparent violations of sanctions against Cuba,
Iran, and Syria. CFM operated dollar banking and securities
accounts on behalf of 11 individual customers located in
sanctioned jurisdictions and conducted dollar business on behalf
of these customers through the US financial system.
In the CAIS example, the US Treasury said the organization
operated dollar banking and securities accounts for the 17
persons for a period of over three years.
A total of 240 transactions, comprising $2,050,780, breached US
sanctions. CAIS also allowed these customers to engage in 33
commercial transactions totaling around $1,025,400 through US
banking correspondents in apparent violation of
US sanctions.
“CAIS had reason to know that these transactions involved clients
residing in sanctioned jurisdictions because at the time of the
apparent violations the account holders’ know-your-customer files
included corresponding address information indicating their
residence in sanctioned jurisdictions,” the Treasury
said.
“The settlement amount reflects OFAC’s determination that CAIS’s
apparent violations were voluntarily self-disclosed and
constitute a non-egregious case,” it said.
In the CFM case, the Treasury said this entity collects account
holders’ KYC data, including addresses of such account holders,
but from December 2011 until July 2016, CFM allowed customers
located in the sanctioned jurisdictions to purchase securities
issued by US companies through US broker-dealers and other US
market participants. A total of 410 transactions took place,
totaling $966,491. CFM also allowed these customers to engage in
16 commercial transactions totaling about $267,476 through US
banking correspondents in apparent violation of US sanctions.
(Editor's note: The acronym “CAIS” is not to be conflated with
the US-based alternative investment platform of the same name,
which is a separate business unconnected to Indosuez.)