Case No. GLOMAG-2019-363474-1 (Application included)

Date issued: Nov. 05 2021

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TURBOFAC Commentary (382 words)

Notes:

1) Case No. GLOMAG-2019-363474-1 arises from a wire, initiated on 10/16/2018, to a beneficiary (Falcon Strategic Solutions D.O.O.) that was not added to the SDN list until 9/12/2019. The beneficiary, however, "was established by [an SDN individual] immediately following his December 21, 2017 designation to avoid sanctions" (https://home.treasury.gov/news/press-releases/sm849).

According to the government in a forfeiture complaint aimed at forfeiting the funds blocked, "Partizan Tech DOO (“Partizan Tech”), Tehnoglobal Systems DOO Beograd (“Tehnoglobal”), and Grawit Limited [all SDNs]...used a series of front companies, including Falcon, Finrost, and Vectura, to continue conducting correspondent banking transactions through the U.S. financial system, in violation of the International Emergency Economic Powers Act..." (See p. 3, PDF). "[Falcon Strategic Solutions D.O.O.] was established on or about December 29, 2017, and was utilized to receive payments on behalf of Partizan...