Discover Financial Services OFAC Settlement: $8.7K

OFAC alleged that Discover dealt in property in the United States in which a Specially Designated Narcotics Trafficker (SDNTK) had an interest by maintaining a personal credit card account on his behalf. Discover processed twenty-eight transactions through this personal credit card account. The value of the transactions processed over three years totaled $23,252. The apparent violations occurred from on or about December 15, 2005, to on or about November 24, 2007, under the Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598.

The base penalty amount for the apparent violations was $11,626. Discover voluntarily disclosed this matter to OFAC. The settlement amount of $8,720 reflects OFAC's consideration of General Factors, including the voluntary self-disclosure. Discover had no other known violations on record with OFAC prior to these allegations.

As a result of these apparent violations, Discover took several steps to strengthen its OFAC compliance program and its existing OFAC procedures, assigning a new employee to review the credit card portfolio against SDN list updates and providing extra training to its employees.

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