Enforcement: Sanctions : OFAC - Discover Financial Services
21 December 2010 : OFAC releases details of action and penalties against Discover Financial Services, Riverwoods, Illinois, USA.
Discover Financial Services, Riverwoods, Illinois (“Discover”) has remitted USD8,720.00 to
settle allegations of breaches of the Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R.
part 598 (the “Regulations”) occurring from on or about 15 December, 2005 to on or about 24
November, 2007.
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 totalled USD23,252.
The base penalty amount for the apparent breaches was USD11,626.
The settlement amount reflects OFAC’s consideration of the following General Factors: Discover voluntarily disclosed this matter to OFAC.
As a result of these apparent breaches, 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.
Discover has no other breaches on record with OFAC prior to these allegations.
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