On August 27, 2015, the Treasury’s Office of Foreign Assets Control (OFAC) issued a statement [3] regarding a $1,700,100 settlement reached with Swiss bank UBS “for 222 apparent violations of the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 [4].”  According to the settlement notice [5], UBS processed transactions involving securities held in the U.S. for a client who had been designated by OFAC in 2001 as a person who commits, threatens to commit, or supports terrorism. Even though UBS reacted to sanctions that Switzerland imposed against the client by placing blocks and restrictions on the client’s accounts, it “continued to engage in investment-related activity on behalf of the Client, including processing USD securities-related transactions to or through the United States.”  These transactions did not generate alerts pursuant to the bank’s OFAC policy as the client’s name was only identified in internal entries of UBS itself. Considering the “General Factors under OFAC’s Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A [6].,” OFAC found that “UBS acted with reckless disregard for U.S. sanctions requirements by failing to implement adequate controls to prevent the apparent violations from occurring despite receiving numerous warning signs that its conduct could lead to violations of U.S. sanctions laws.”