On March 23, Department of the Treasury’s OFAC announced a settlement agreement with a large money services business (MSB) for failing to implement an effective compliance program “to identify, interdict, and prevent transactions in apparent violation of the sanctions programs administered by OFAC.” According to the settlement, prior to the MSB’s 2013 “long term solution” to screen its transactions in real time against OFAC’s List of Specially Designated Nationals and Blocked Persons (the “SDN List”), deficiencies in the company’s transaction monitoring compliance procedures allowed for the processing of hundreds of transactions with OFAC-sanctioned individuals and countries. Specifically, OFAC alleged that from October 20, 2009 to April 1, 2013, the MSB processed over 100 transactions to or from an account registered to an individual on the SDN List because its “automated interdiction filter” did not initially identify the account holder as a potential match to the SDN List, and when it did, the MSB Operations Agents dismissed alerts on six separate occasions after failing to obtain or review documentation corroborating the identity of the SDN. Under the terms of the agreement, the MSB will (i) pay over $7 million to the Department of the Treasury and (ii) within six months, provide OFAC a summary of the company’s current policies and procedures as they relate to screening transactions and/or customers” to ensure compliance with OFAC regulations.