On March 30, the Federal Reserve Board announced that it fined Wells Fargo $67.8 million for “deficient oversight” that resulted in U.S. sanctions violations. The Board took this action in conjunction with the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), which imposed a separate $30 million penalty on Wells Fargo Bank for the same violations.
From approximately December 2010 to December 2015, Wells Fargo provided a trade finance software platform, called “Eximbills,” to an unnamed European Bank that “used the software to process 124 transactions involving sanctioned parties or jurisdictions,” totaling approximately $532 million, according to the OFAC settlement agreement.
“None of the payments associated with these transactions were processed by Wells Fargo or any other U.S. bank,” OFAC stated. “Accordingly, Wells Fargo engaged in apparent violations of the Iranian Transactions and Sanctions Regulations.”
According to the order of the Board of Governors, Wells Fargo, as a large and complex bank holding company, was “required to maintain a firmwide risk management and oversight framework for identifying and addressing legal and compliance risks.”
This framework, however, “failed to identify and address the legal and compliance risks with respect to the bank’s provision of Eximbills to the foreign bank,” which “constituted an unsafe or unsound practice and enabled the bank to violate OFAC regulations,” the Board’s order stated.
In December 2015, Wells Fargo “self-identified the issue, stopped allowing the foreign bank to process transactions involving parties in jurisdictions subject to OFAC regulations, and no longer offers the trading platform to foreign banks,” the Board’s order stated. Wells Fargo further reported the matter to relevant regulators, including to the Board of Governors and OFAC.
According to the Board’s order, the violations have since been remediated. Additionally, Wells Fargo “strengthened its firmwide compliance with OFAC regulations,” and “fully cooperated with the Board of Governors.” 
Jaclyn Jaeger is a contributing editor at Compliance Chief 360° and a freelance business writer based in Manchester, New Hampshire.