Civil Enforcement Information - Barclays Bank Plc (Second action)

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 (423 words)

Notes:

1) There is technically strict liability one way or the other, but this enforcement action builds on others in different contexts (see e.g. Barracuda Networks (2015), Stanley Drilling Equipment & Supply, Inc.(2012)) suggesting that automated screening will not suffice to meet OFAC's diligence expectations when there is "publicly available" information on the prohibited nature of a party and/or transaction. This also obviously suggests that the document provided by a customer in ordinary procedures do not satisfy OFAC's diligence expectations.

2) As of the date on which the enforcement release was issued, this was the only enforcement action based on a person's failure to determine that a person was blocked pursuant to the 50% rule. See also Cobham Holdings, Inc. (2018).

Civil Enforcement Information - Intesa Sanpaolo S.p.A. (2013)...

Welcome!

Welcome!

Civil Enforcement Information - Barclays Bank Plc (Second action)

TURBOFAC Commentary (423 words)