On 30 March 2023, Wells Fargo agreed to remit $30 million to settle its penalty liability across multiple sanctions programs with US Department of the Treasury’s Office of Foreign Asset Controls (“OFAC”).1 Across several years, Wells Fargo and its predecessor in Europe, Wachovia Bank, provided software that was used to process transactions with US-sanctioned jurisdictions and persons.
Wells Fargo acquired Wachovia and inherited Wachovia’s trade insourcing relationships, including a relatio...
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