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financial institutions from opening and operating accounts for employees of the North Korean mission. The
software used to screen customers at account opening allegedly relied heavily on a list of politically exposed
persons and did not include the names of government employees of sanctioned countries.
In the second matter, the bank maintained two accounts over a four-year period for Esperanza Caridad
Maradiaga Lopez, who was designated as an SDN in 2013. In 2016, Lopez opened two accounts at a branch in
Miami, Florida. A bank employee allegedly dismissed an alert that flagged for the bank's compliance
department the possible match with the SDN List because there was no full match on the person's name, date
of birth, and geographical location. OFAC said that four additional alerts for Ms. Lopez were generated, all of
which were manually dismissed by bank employees, though her accounts were finally closed after a reviewer
determined the alert to be a true hit. The asserted compliance failures, including human errors and a breakdown
in official compliance procedures, led to 145 apparent violations of the Foreign Narcotics Kingpin Sanctions
Regulations. OFAC noted that the apparent violations in both matters were voluntarily self-disclosed and were
non-egregious.
