On October 5, 2018, the US Department of the Treasury, Office of Foreign Assets Control (OFAC) announced an agreement with JPMorgan Chase Bank, N.A. (JPMC) to settle potential civil liability arising from 87 apparent violations of the Cuban Assets Control Regulations, the Iranian Transactions and Sanctions Regulations, and the Weapons of Mass Destruction Proliferators Sanctions Regulations. According to OFAC, “the transactions were net settlement payments, of which a very small portion appears to have been attributable to interests of airlines that were at various times on OFAC’s List of Specially Designated Nationals and Blocked Persons (the “SDN List”), blocked pursuant to OFAC sanctions, or located in countries subject to the sanctions programs administered by OFAC.” Under the terms of the settlement agreement, JPMC agreed to pay a civil monetary penalty of US$5,263,171.

Separately, OFAC issued a Finding of Violation (without penalty) to JPMC regarding violations of the Foreign Narcotics Kingpin Sanctions Regulations and the Syrian Sanctions Regulations. According to OFAC, “between August 4, 2011 and April 29, 2014, JPMC processed 85 transactions totaling $46,127.04 and maintained eight accounts on behalf of six customers who  were contemporaneously identified on the SDN List.”