The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued a Finding of Violation to BMO Harris Bank NA (“BMO Harris”), as the successor to Marshall and Ilsley Bank (“M&I Bank”), in connection with M&I Bank’s processing of six funds transfers totaling $67,357. M&I Bank originated these six funds transfers on behalf of its customer in early 2011, prior to its merger with Harris NA, in violation of § 560.204 of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR). Subsequent to processing these funds transfers, M&I Bank merged with Harris NA on July 5, 2011 to form BMO Harris.
This enforcement action highlights the particular sanctions risks associated with failing to implement proper procedures and controls to ensure that internal proprietary sanctions lists are properly reviewed following changes to the SDN List and/or to the sanctions programs administered by OFAC. OFAC has also issued guidance regarding the use and maintenance of false hit lists.
For more information on this action, please visit the following web notice.