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Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and American Express National Bank

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The United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a settlement with American Express National Bank (Amex), a subsidiary of American Express Company.  Amex agreed to remit $430,500 to settle its potential civil liability for 214 apparent violations of OFAC’s Kingpin sanctions.  Over the course of two months, Amex processed transactions for an account whose supplemental card holder was designated in connection with illegal drug distribution and money laundering.  A combination of human error and sanctions compliance program deficiencies enabled the account to engage in $155,189.42 worth of transactions.  The settlement amount reflects OFAC’s determination that the apparent violations were not voluntarily self-disclosed and were non-egregious.

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