Bank of America’s sanctions settlement: the failures behind the fine.
A review of the official record shows how a payment-routing problem accounted for most of the value in OFAC’s case—and why the broader penalty headline needs careful reading.
THE NORTHGATE DESKS
Investigations
Follow the document. Test the claim. Examine the evidence behind questions of public interest.
OPENING EDITION · 02 CONTRIBUTIONS
A leaked document is a starting point. It is not a verdict.
A practical framework for separating an authentic record from the larger claim someone wants it to prove.
