Civil Enforcement Information - JPMorgan Chase Bank N.A. (2nd violation, Finding of Violation Component)

Date issued: Oct. 05 2018

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (419 words)

Notes:

1) See also Civil Enforcement Information - JPMorgan Chase Bank N.A. (2nd violation, Settlement Agreement Component). This is the second enforcement action in which OFAC notices to the public a settlement agreement and a separate finding of violation (see also Civil Enforcement Information - Toronto-Dominion Bank and Civil Enforcement Information (FOV) - TD Bank, N.A. We treat the violations connected to the settlement agreement as an enforcement action separate from the Finding of Violation.

3) This is one of a small handful of enforcement actions stemming from a failure to flag SDNs where the names on the payment messages did not match those on the SDN list. In the other, National Bank of Pakistan (2015), the violation was less forgivable since the filter failed to catch what was otherwise an exact match with...