Wells Fargo added to its Grand Slam of Enforcement with its recent settlement of OFAC violations and paid $30 million to settle the matter.

Wells Fargo’s violations occurred during a seven-year period, 2008 to 2015, and stemmed from its acquisition of Wachovia Bank.  Wells Fargo provided a foreign bank (part of predecessor Wachovia) with trade-finance software that Wachovia used to process trade financing transactions with U.S.-sanctioned entities and individuals.  Wachovia customized the software and then used it to conduct transactions that it knew or should have known would involve sanctioned entities and individuals.

In this Episode, Michael Volkov reviews the Wells Fargo OFAC settlement.