Case No. MUL-2013-304207-1

Date issued: Sep. 10 2015

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TURBOFAC Commentary (247 words)

Notes:

1) The applicant bank asks about whether it can establish a relationship with a U.S. subsidiary of a Chinese entity that is known to have business in China and Cuba. The applicant notes that it required confirmation that the customer would not “conduct any transactions ‘with funds derived from the proceeds of business transactions conducted with OFAC sanctioned countries.’” OFAC cites to the broad prohibitions of the ITSR and CACR and concludes that “it does not appear as though [U.S. person customer] is directly or indirectly involved in [parent’s] operations in Iran or in transactions in which Cuba or a Cuban national has an interest. Therefore, [U.S. applicant’s] maintenance of accounts and provision of services to [U.S. person] would not be prohibited by the CACR or the ITSR.” The...