Wells Fargo Bank, N.A. OFAC Settlement: $67.5K (2010)

Wells Fargo exported financial services to Iran by performing financial services in the United States on behalf of an account holder while the account holder was located in Iran. The transactions occurred between March 2005 and July 2006 and totaled $55,959.62 in value.

Wells Fargo did not voluntarily disclose this matter to OFAC. The base penalty amount for the apparent violations was $90,000. The settlement amount of $67,500 reflects OFAC's consideration of General Factors. OFAC expressed interest in this account holder as early as April 2002, but Wells Fargo failed to conduct an investigation until September 2006. There were three prior penalty cases against Wells Fargo for violations of the Regulations. Wells Fargo created and implemented a risk-based OFAC compliance program, which includes the use of Internet Protocol addresses to identify registered users located in Iran. Wells Fargo also established open and timely communications with OFAC, and entered into two tolling agreements with OFAC.

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