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OFAC has issued a "Finding of Violation" in respect of breaches of the Global Terrorism Sanctions Regulations relating to the maintenance of Iranian-owned aircraft. The subject of the order no longer exists but OFAC has proceeded anyway.


If we take out the hyperbole inherent in American notices (e.g. "violation" instead of "breach" and the profligate use of words like "egregious") we get to a nitty gritty that is a stone in the shoe, a thorn in the side or any one of a dozen bon mots that indicate how and why compliance officers need to be abreast of principles more than data. One has to feel some sympathy with State Street. The case also have implications for citizens of one country living abroad, especially pensioners.


Yesterday, US President Trump announced the long-telegraphed withdrawal of the USA from the Iran nuclear sanctions agreement, known as the Comprehensive Plan of Action. According to the US Treasury "The President confirmed that the US will begin the process of re-imposing all US sanctions previously waived under the JCPoA." That's going to cause huge complexity for businesses all over the world because no other government of any international importance is adopting the USA's position. Also, there's a gold-rush about to start.

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Yesterday, the USA's President Trump announced that the US would leave the Joint Comprehensive Plan of Action a.k.a. the Iran Nuclear Deal. Below is a list of resources.

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As PoTUS Trump continues to ramp up his rhetoric against North Korea and Iran, the FATF recently issued a statement relating to both countries. While there is accord about NoKo, the FATF and the USA do not speak as one with regard to Iran. Is this a problem?

Chinese telecommunications giant ZTE and its subsidiaries and associates were investigated for "apparent" breaches of US sanctions, in particular a trade embargo with Iran.

Zhongxing Telecommunications Equipment Corporation is incorporated in China and has subsidiaries and "affiliates throughout the world that conduct business on ZTE and on its behalf," according to OFAC.

A civil penalty has been applied. No prosecution will take place. There is a finding of no fault despite what OFAC calls "an egregious case."

The cult of paying various US government departments, or "agencies" to say nothing of state prosecutors, to to avoid prosecution using the dubious formula of "without admitting or denying the allegations" has reached a new height as a Canadian banking group has "agreed to remit USD516,105 to settle its potential civil liability."

Note "potential." Are such deals evidence of bribery ("we'll give you money if you leave us alone") or of blackmail ("give us money or we'll cost you a fortune in dealing with a long and complex, and heavily disruptive investigation that we all know will turn up something in even the best run companies. And yes, of course we know you aren't American")

The trouble is: there were extensive compliance failures and, as in so many cases, a failure by a non-US bank to recognise the long arm of US law and regulation where US dollars are used.

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