The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a settlement with Nasdaq, Inc. Nasdaq agreed to remit USD4,040,923 to settle its potential civil liability for a (former) wholly owned foreign subsidiary’s apparent breach of sanctions on Iran.

The former subsidiary engaged in the export of services to Iran and the Government of Iran, thereby committing 151 apparent breaches of OFAC sanctions on Iran. The settlement amount reflects OFAC’s decision that Nasdaq’s conduct was non-egregious and voluntarily self-disclosed.

In February 2008, Nasdaq acquired OMX AB, a Swedish financial company that owned and
operated the Armenian Stock Exchange , which after the acquisition was named Nasdaq OMX Armenia OJSC.

Nasdaq OMX Armenia OJSC (Nasdaq OMX Armenia), the former owner and operator
of the Armenian Stock Exchange (ASE) processed trades and settled payments through the ASE platform involving the OFAC-designated Armenian subsidiary of Iran’s state-owned Bank Mellat. In doing so, Nasdaq OMX Armenia knowingly engaged in the exportation of services to Iran and the Government of Iran, thereby committing 151 apparent breaches of OFAC sanctions on Iran.

Full notice: https://ofac.treasury.gov/media/932386/download?inline