On 17 December 2013, HSBC Bank USA, N.A., a US subsidiary of the British financial services company HSBC Holdings plc, agreed to pay $32,400 in settlement of three apparent violations of the Global Terrorism Sanctions Regulations. HSBC voluntarily disclosed the violations, and OFAC concluded that the apparent violations were not the result of wilful or reckless conduct. The alleged violations relate to HSBC Bank USA’s processing of US-dollar funds transfers originated by Tajco, an entity that is designated for sanctions as a Specially Designated Global Terrorist, destined for an unrelated company’s account at HSBC Bank Middle East Limited. According to OFAC, HSBC’s interdiction software flagged a potential match, but the bank’s compliance personnel erroneously allowed the transactions to proceed.

OFAC enforcement announcement (PDF)