On July 15, 2022, the OFAC announced a settlement with American Express National Bank (Amex) to settle its potential civil liability for 214 apparent violations of OFAC’s Kingpin sanctions. Amex agreed to remit $430,500, which reflects OFAC’s determination that the apparent violations were not voluntarily self-disclosed and were non-egregious.
According to the OFAC’s investigation, Amex processed transactions for an account whose supplemental card holder was designated in connection with illegal drug distribution and money laundering over the course of two months. Human error and sanctions compliance program deficiencies were determined as factors which enabled the account to engage in $155,189.42 worth of transactions.
The OFAC’s enforcement action highlights the importance of properly training employees on sanctions compliance procedures and ensuring that those procedures are followed appropriately, especially when high confidence alerts are generated.
Read the OFAC’s release here.
The full enforcement action can be found here.
