Compass Bank OFAC Settlement: $19.1K (2013)

On February 10, 2011, Compass originated an £8,900 (approximately $14,898) wire transfer on behalf of an individual customer, destined for a third-country company's account at a financial institution in the United Kingdom. An invoice accompanying the wire transfer request indicated that the purpose of the transaction was a payment for the shipment of a tractor from the United Kingdom to Omdurman, Sudan. A Compass OFAC Assistant Manager and a Compass BSA OFAC Manager reviewed the wire request and associated invoice, and determined that the payment did not violate the SSR because none of the parties involved were on the List of Specially Designated Nationals and Blocked Persons, and because they mistakenly concluded that the underlying purpose of the payment was authorized pursuant to a general license. This conduct gave rise to one apparent violation of §§ 538.205 and 538.206 of the Sudanese Sanctions Regulations, 31 C.F.R. part 538.

OFAC determined that Compass did not voluntarily self-disclose the apparent violation and that the apparent violation constituted a non-egregious case. OFAC concluded that the apparent violation was not the result of willful or reckless conduct. The total base penalty amount for the apparent violation was $25,000. OFAC further reduced the proposed penalty in light of Compass' agreement to settle its potential liability for the apparent violation, resulting in a final settlement amount of $19,125.

This page summarizes an OFAC enforcement case based on the document archived below. SanctionsLookup assumes no liability for errors, omissions, or inaccuracies in the original documents, this summary, or any changes made to the source documents at any time.

Provided for informational purposes only and does not constitute legal or compliance advice. Always consult the source document directly rather than relying on this summary.