Ed Wilson published "When Screening for Bad Guys, Matching Names No Longer Enough" in American Banker on October 1, 2013.
In a little-noticed civil penalty release in June 2013, the Office of Foreign Assets Control, the U.S. Treasury office responsible for administering and enforcing economic sanctions, raised the bar on acceptable checking practices and potentially exposed many banks and other financial institutions to penalties.
The importance of the case – between OFAC and Wells Fargo – is not in the relatively small amount of the fine. Rather, it is in the rationale for the fine and the critical impact this case will have on bank compliance practices from now on.
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