Enforcement: OFAC - Wells Fargo Bank
Wells Fargo Bank provided internet banking services to a customer while he was in Iran and after OFAC had "expressed an interest" in the customer to the bank. Remedies include IP address monitoring to geo-locate the whereabouts of customers.
Wells Fargo Bank, N.A. (“Wells Fargo”) has remitted USD67,500 to settle allegations of breaches of the Iranian Transactions Regulations, 31 C.F.R. part 560 (the “Regulations”) occurring between March 2005 and July 2006.
OFAC alleged that 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 value of the transactions totalled USD55,959.62.
Wells Fargo did not voluntarily disclose this matter to OFAC.
The base penalty amount for the apparent breaches was USD90,000.
The settlement amount reflects OFAC’s consideration of the following General Factors: OFAC expressed to Wells Fargo an interest in this account holder as early as April 2002 but Wells Fargo failed to conduct an investigation until September 2006.
There are three prior penalty cases against Wells Fargo for breaches 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 established open and timely communications with OFAC, and entered into two tolling agreements with OFAC.
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