On February 10, 2016, the U.S. Treasury’s Office of Foreign Asset Control (OFAC) reached a settlement with Barclays Bank for apparent violations of the Zimbabwe sanctions regulations. According to the enforcement notice [3], “Barclays processed 159 transactions totaling approximately $3,375,617 to or through financial institutions located in the United States . . . for or on behalf of corporate customers of Barclays Bank of Zimbabwe . . . that were owned . . . by a person identified on the U.S. Department of the Treasury’s . . . List of Specially Designated Nationals and Blocked Persons.” According to a news report [4], beginning around 2005, local regulations in Zimbabwe prevented Barclays from implementing effective compliance procedures in that country, which led to the British branch performing the checks on cross-border transactions remotely, based on the Zimbabwe’s branch electronic records. This system led to errors, as the Zimbabwe branch failed to update paper records and their corresponding electronic records, which were used for the compliance screening. After U.S. authorities blocked several transactions to a designated firm, Barclays “failed to upload identifying information for this entity to its sanctions screening filter in a timely or accurate manner.” OFAC found that Barclays failed to take adequate action “despite numerous warning signs that its conduct could lead to a violation of US sanctions,” and noted that senior and managerial personnel had reason to know of the potential for violations.