Banco Colpatria OFAC Settlement: $91.8K (2010)

OFAC alleged that Colpatria Miami violated the Narcotics Trafficking Sanctions Regulations ("NTSR") by processing 26 dollar-denominated wire transfers on behalf of one Colpatria corporate client between November 22, 2004 and May 24, 2005, after OFAC designated the corporate client's beneficial owners as Specially Designated Narcotics Traffickers ("SDNTs"). Although Colpatria Miami screened the names of the beneficial owners against the Specially Designated Nationals and Blocked Persons List ("SDN List") at the time the account was opened, it did not screen the names as the SDN List was updated. After discovering that the corporate client's beneficial owners had been designated as SDNTs, Colpatria Miami voluntarily self-disclosed this matter to OFAC.

The base penalty amount for the alleged violations was $229,623. The settlement amount reflects OFAC's consideration of the following General Factors: Colpatria Miami voluntarily self-reported this matter to OFAC; Colpatria Miami has no history of any OFAC violations; Colpatria Miami revised its software configuration to review automatically the names of authorized signatories and beneficial owners of accounts rather than just the names of the account holders when performing account opening and periodic name checks against OFAC's SDN List; and Colpatria signed a tolling agreement with OFAC.

Colpatria Miami screened the names of beneficial owners against the SDN List at account opening but did not repeat those checks as the SDN List was updated. As part of its remediation, Colpatria Miami revised its software configuration to automatically review the names of authorized signatories and beneficial owners of accounts, rather than just the names of the account holders, when performing both account opening and periodic name checks against OFAC's SDN List.

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