On 24 July, OFAC announced that Bank of America, N.A. agreed to pay $16,562,700 to settle potential liability for apparent violations of the Kingpin Act. According to the Factual Statement in the settlement agreement, Bank of America appears to have processed 208 transactions on behalf of, and failed to block five accounts owned by, 10 individuals on the SDN List between September 2005 and March 2009.  The apparent violations appear to have occurred because of a deficiency in Bank of America’s screening and filtering processes, and the settlement agreement asserts that Bank of America became aware of this deficiency on 6 October 2006.  OFAC determined that the apparent violations that occurred after this date constituted an egregious case.  Finally, although many of the apparent violations were disclosed by Bank of America, OFAC determined that the disclosures did not qualify as voluntarily self-disclosed under the Economic Sanctions Enforcement Guidelines because OFAC was already aware of substantially similar apparent violations prior to the disclosures.

OFAC Enforcement Announcement (PDF)

OFAC – Bank of America Settlement Agreement (PDF)