Compass Bank OFAC Settlement: $607.5K (2010)

OFAC alleged that Compass Bank acted without an OFAC license or outside the scope of its license by initiating three funds transfers on behalf of one of its clients related to the petroleum or petrochemical industries in Sudan. The apparent violations occurred during September 2006.

Compass Bank did not voluntarily disclose this matter to OFAC and the alleged violation constituted a non-egregious case. The base penalty amount was $750,000. The settlement amount of $607,500 reflects OFAC's consideration of the following General Factors: Compass Bank had not previously received a Penalty Notice or Finding of Violation from OFAC; fully cooperated with OFAC during its investigation of this matter; and undertook significant remedial actions to strengthen its OFAC compliance program and to manage potential sanctions risk, not just in the area of funds transfers but more broadly across its entire business line.

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