Enforcement Release - Wells Fargo Bank, N.A.

Date issued: Mar. 30 2023

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TURBOFAC Commentary (2331 words)

Consolidated Comment on the Wells Fargo Bank, N.A. (3rd action) Enforcement Release and Associated Settlement Agreement

1) RELATIONSHIP BETWEEN THE ENFORCEMENT RELEASE AND SETTLEMENT AGREEMENT

In a first for OFAC, OFAC has released a settlement agreement of which the “Factual Statement” is reproduced word-for-word in the main Enforcement Release. The Wells Fargo ("WF") Settlement Agreement does not contain any notable information about the violation that the Enforcement Release web post does not contain, except that the Settlement Agreement confirms that “[n]one of the payments associated with these [sanctions-implicating] transactions were processed by Wells Fargo or any other U.S. bank.” The relevance of this is discussed further below. Note that the “Terms of Settlement” here are substantially similar to those found in the last settlement agreement published by OFAC (Settlement Agreement (OFAC) - Alfa Laval Middle East Ltd. (April, 2021))....