Civil Enforcement Information - Union de Banques Arabes et Françaises

Date issued: Jan. 04 2021

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TURBOFAC Commentary (951 words)



The first 127 violations cited in the “Union de Banques Arabes et Françaises” case are similar in kind to those discussed in the General Note on Enforcement Actions Resulting From “Bank-to-Bank” Transactions that Only Indirectly Involve Sanctions Targets (“Complex Payment Structures,” Structured Transactions, etc.)

In that note, we discuss various violations that OFAC has found where a bank processes transactions through the U.S. financial system that do not relate directly to any sanctioned person, but are related to other transactions that do directly relate to a sanctioned person. In general, the transaction that is processed through the U.S. financial system (Transaction A) is one that would not constitute a sanctions violation if not for its relationship to the second transaction (Transaction B), and Transaction B is one that would, but for its relationship to...