On April 30, 2020, OFAC issued a “Finding of Violation” to American Express Travel Related Services Company (“Amex”) for violations resulting from processing transactions for a person designated as a “Specially Designated National” (i.e. SDN list). In their release, OFAC explains that they found that Amex issued a prepaid card to, and processed 41 transactions totaling $35,246.82 on behalf of, Gerhard Wisser, who was on the SDN list. OFAC explains that these violations were the result of human error and screening system defects and Amex remediated and disclosed the violations to OFAC. Fortunately for Amex, there is no monetary penalty associated with a Finding of Violation.
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