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The consent order with Barclays followed an investigation conducted jointly by the Department of Justice, the district attorney for the County of New York, N.Y., and OFAC into Barclays practices concerning the transmission of funds to and from the U.S., including through its New York branch, by and through entities and individuals subject to sanctions regimes imposed under the International Emergency Economic Powers Act
(IEEPA) and the Trading with the Enemy Act, both of which are administered by OFAC. Barclays agreed to pay an aggregate $298 million in settlement agreements with the Justice Department, New York district attorney and OFAC; and to implement a global OFAC compliance program.
The 2013 order with Oklahoma Capital Bank required the bank to strengthen management and board oversight, strengthen credit risk management, establish a written enhanced lending and credit administration program, submit plans to ensure sufficient capital and to enhance interest-rate risk management, and more.
2013 order, Oklahoma Capital Bank (formerly known as Freedom Bank of Oklahoma), Tulsa, Okla.