Civil Enforcement Information - MID-SHIP Group LLC

Date issued: May. 02 2019

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TURBOFAC Commentary (1466 words)

Notes:

1) Further factual information available at Settlement Agreement (OFAC) - MID-SHIP Group LLC (2019).

2) BASES FOR LIABILITY

a) OFAC says that:

between on or about February 18, 2011 and on or about November 14, 2011, Respondent appears to have violated § 544.201 of the WMDPSR when Respondent dealt in blocked property or interests in blocked property by processing five electronic funds transfers, totaling approximately $472,861, that pertained to payments associated with blocked vessels identified on OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDN List”).

There are several things notable about this. First there is a recognition that it was only the processing of the payments that was found to violate the law. It is consistent with OFAC's past practice to consider payments...