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Crédit Agricole Units Settle With US Over Sanctions Violations

Tom Burroughes

17 September 2023

(An earlier version of this news item appeared yesterday on Family Wealth Report, our sister news service.)

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 business unit agreed to remit $401,039 for sanctions violations.

The US Department of the Treasury’s Office of Foreign Assets Control this week announced a settlement with the group. CAIS is an indirect subsidiary of Crédit Agricole Corporate and Investment Bank, which is in Switzerland and specialises 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 Crédit Agricole Corporate and Investment Bank located in Monaco that specialises 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 organisation 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 totalling 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, totalling $966,491. CFM also allowed these customers to engage in 16 commercial transactions totalling 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.)