Enforcement Release - Union de Banques Arabes et Françaises

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (929 words)

Notes:

1) THE OFFSHORE BOOK TRANSFERS AND FX TRANSACTIONS

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...

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Enforcement Release - Union de Banques Arabes et Françaises

TURBOFAC Commentary (929 words)