On March 30, 2023, Wells Fargo agreed to remit $30,000,000 to
settle its penalty liability across multiple sanctions programs
with U.S. Department of the Treasury's Office of Foreign Asset
Controls. Across several years, Wells Fargo and its predecessor in
Europe, Wachovia Bank, provided software that was used to process
transactions with U.S.-sanctioned jurisdictions and persons.
What was the Software?
Wells Fargo acquired Wachovia and inherited Wachovia's trade
insourcing relationships, including a relationship with an
undisclosed European bank (deemed "Bank A") that was
engaged in transactions that implicate U.S. sanctions. Wachovia
used two different insourcing software solutions to moderate and
maintain these relationships: the Comprehensive software solution,
one where Wells Fargo processed trade transactions on behalf of the
customer, and the Hosted software solution, one where it provided
the software to the customer and the customer managed the
transaction
