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...
Not that I am a glutton for punishment, but I always find enforcement actions to supply a number of valuable lessons learned. There are always instructive nuggets of information, opportunities missed, and root causes that highlight important compliance messaging and principles. Wells Fargo has unintentionally provided a variety of these important lessons — not from positive behaviors but from a laundry list of violations that...
In our lifetime (however long or short), there is no way any company will ever match Wells Fargo for its record of misconduct, criminal and civil enforcement, and regulatory fines and penalties. No one, no way. 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 is a one-entity...
Matt Stankiewicz, Senior Associate at The Volkov Law Group, rejoins us for a blog posting on OFAC sanctions law. Matt can be contacted at [email protected]. Sanctions law can be complex. The sanctions programs themselves are often a tangled web of do’s and don’t’s – various wind down periods, General Licenses, payment structures, and more. In order to enforce these laws and regulations, OFAC must necessarily...
