Sanctions Evasion Reference

Wells Fargo: software built to host what the bank wouldn't process

Wells Fargo paid OFAC $30 million in 2023 after inheriting a Wachovia platform specially engineered so a European bank could process trade-finance deals with Iran, Sudan and Syria on infrastructure the US bank still controlled.

period

2007–2015

outcome

Settlement

parties

Wachovia Bank; Wells Fargo Bank, N.A.; A European bank ("Bank A")

programmes

Islamic Republic of Iran, Syrian Arab Republic, Sudan

reviewed

2026-10-01

Cite this page
APA 7
Sanctions Evasion Reference. (2026, October 1). Wells Fargo: software built to host what the bank wouldn't process. https://sanctionsevasion.org/cases/wells-fargo-wachovia-eximbills-2023/
Chicago
Sanctions Evasion Reference. “Wells Fargo: software built to host what the bank wouldn't process.” Last reviewed October 1, 2026. https://sanctionsevasion.org/cases/wells-fargo-wachovia-eximbills-2023/.
BibTeX
@misc{ser-cases-wells-fargo-wachovia-eximbills-2023,
  author = {{Sanctions Evasion Reference}},
  title  = {Wells Fargo: software built to host what the bank wouldn't process},
  year   = {2026},
  note   = {Last reviewed 2026-10-01},
  url    = {https://sanctionsevasion.org/cases/wells-fargo-wachovia-eximbills-2023/}
}

The date is when this page was last reviewed, not when it was first published.

Penalties imposed

AuthorityDate AmountNote
OFAC 2023-03-30 $30,000,000 124 apparent violations worth about $532 million; voluntarily self-disclosed, egregious. Statutory maximum $1,066,738,422.22; base penalty $533,369,211.

Not a bank that failed to notice a customer’s sanctioned dealings. A bank that built the tool specifically so a customer could do them on the bank’s own infrastructure, in a version designed from the start to be outside the bank’s own view.

Two versions of the same software

Wachovia sold a trade-finance platform called Eximbills to foreign banks in two forms. “Comprehensive” meant Wachovia processed the client’s trade transactions itself, under its own screening. “Hosted” meant Wachovia supplied the software and the client ran its own transactions on it. In 2006, Wachovia and a European bank (“Bank A”) agreed in writing that Bank A would keep sanctioned-jurisdiction business off the Hosted platform entirely, using separate systems Wachovia had no part in.

In 2007, Bank A asked to consolidate onto one platform — including the sanctioned-jurisdiction business. A mid-level Wachovia manager agreed. Wachovia built Bank A a customized Hosted version specifically so it could manage trade instruments involving Iran, Sudan and Syria, running on Wachovia’s — and after 2008, Wells Fargo’s — own technology infrastructure in Hong Kong and North Carolina. The software even included a redirect: if Bank A accidentally routed a sanctioned-jurisdiction transaction to the screened Comprehensive side, the system sent it back to the unscreened Hosted side automatically.

Seven years of a plan that was never run

Wells Fargo acquired Wachovia in 2008 and inherited the relationship. Staff raised sanctions concerns about it internally more than once over the following years — after two major OFAC enforcement cases in 2012 and 2013 prompted renewed attention, a working group was formed, identified “potential facilitation-related concerns,” and drew up a three-point plan: tighten contract language, obtain periodic compliance certifications from Bank A, and audit its Eximbills data.

The plan was never carried out. It was folded into a larger, slower review of the whole trade insourcing business, and Bank A kept using the Hosted platform for sanctioned-jurisdiction trade for at least two more years. A 2014 internal audit of the insourcing business line skipped the Hosted Eximbills product specifically, relying on the business line’s own assessment that it was low-risk. The gap was closed only in late 2015, during an unrelated business review, when it surfaced that Bank A might have been using the platform this way since 2008 — seven years after the fact. Wells Fargo cut off access immediately and self-disclosed.

What ties the two findings together

Providing a counterparty the specific means to transact with sanctioned jurisdictions is the professional-enablers pattern applied to software rather than legal or financial services — the platform did the enabling that a formation agent or nominee usually does. And a known, documented plan to test and audit that exposure that was drawn up and then never executed is exactly the gap untested screening controls describes: the firm did not fail to notice the risk. It identified the risk, planned a response, and did not complete it for years.

The penalty

Egregious and voluntarily self-disclosed. OFAC called the seven-year gap between acquisition and discovery “reckless disregard,” while crediting that senior management never directed or knew of the arrangement, that Wells Fargo’s broader compliance programme was otherwise strong, and that most of the 124 violations involved goods — agriculture, medicine, telecommunications — that might well have qualified for a licence had one been sought.

What the record shows

  • A tool built for one purpose can be re-engineered for another. The redirect mechanism existed to make the unscreened pathway more convenient for Bank A, not to conceal anything — but its effect was to keep sanctioned-jurisdiction business permanently outside Wells Fargo’s own screening.
  • Identifying a risk is not the same as closing it. A working group, a three-point plan and a documented “potential facilitation” finding sat on file for roughly two years while the business kept running.

Techniques this case demonstrates

Programmes and jurisdictions in this case

  • Iran sanctions — A layered set of US, EU and UN measures dating from 1979 and substantially rebuilt after 2018, covering energy, finance, shipping, and proliferation-related procurement.
  • Syria sanctions — US, EU and UK measures restricting dealings with the Syrian government, its energy sector and designated parties, with substantial humanitarian carve-outs.
  • Sudan sanctions — A US embargo regime from 1997, revoked in 2017 and followed by targeted measures. Its main relevance here is historical: several of the largest penalties in OFAC's record concern conduct from the years it was in force.

Enforcement documents and sources

  1. OFAC Settles with Wells Fargo Bank, N.A. for $30,000,000. U.S. Department of the Treasury, Office of Foreign Assets Control, 2023. Enforcement release, 2023-03-30, US$30,000,000.
  2. A Framework for OFAC Compliance Commitments. U.S. Department of the Treasury, Office of Foreign Assets Control, 2019. Risk Assessment, Mergers and Acquisitions (M&A); Root Causes, item III; General Aspects of an SCP, Testing and Auditing.

All enforcement cases