The Treasury's Office of Foreign Assets Control said the bank had handled 222 US securities transactions worth $2.5 million between 2008 and 2013 on behalf of an individual client who was blacklisted by OFAC under US sanctions.
The client was not identified by the Treasury, but it said the transactions benefited a person or group named by the United States as a “specially designated global terrorist.”
The Treasury said that although a number of people in UBS's compliance department knew of the client's OFAC designation, “the bank failed to implement any steps or measures to prevent UBS from processing transactions for the client to or through the United States.”
The UBS settlement agreement with OFAC labeled the transactions “apparent” because UBS at the time had considered them internal to the bank and so not in violation of US rules.
OFAC credited UBS with generally adhering closely to sanctions rules, with “substantially” cooperating in the investigation, and for having taken remedial action after the problem surfaced.
The penalty paid was much less than the base possible penalty in the case of $3.78 million.