Compass Bank of Birmingham, Alabama, agreed to pay $19,125 to settle with OFAC an alleged violation of the Sudanese Sanctions Regulations. On 10 February 2011, Compass Bank originated a wire transfer to the United Kingdom for approximately $15,000. The transfer went to a third-country company’s account at the UK financial institution, and the funds were ultimately intended as payment for the shipment of a tractor from the UK to Omdurman, Sudan. Both an OFAC Assistant Manager and BSA OFAC Manager reviewed the wire transfer request at Compass Bank and, mistakenly, concluded that the underlying purpose of the payment was authorised pursuant to a general licence. OFAC determined that the apparent violation was a non-egregious case and that the mitigating factors included that another institution successfully interdicted and rejected the transaction, Compass Bank cooperated in the investigation, and Compass Bank took appropriate remedial action. OFAC found as an aggravating factor that Compass Bank managers with primary responsibility for compliance demonstrated a lack of understanding of the Sudanese Sanctions Regulations.