OFAC Enforcement

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 (300 words)

Notes:

1) While the causing of the export of custodial services was covered by Clearstream Banking S.A. (2014), the UBS AG case is the first in which a wider variety of "passive" services were considered distinct violations of the sanctions violations.

The receipt of dividends on U.S. securities and payments of management fees, for example, are activities which are normally not directly ordered by a client, but rather are performed on the basis of a single delegated authority.

3) The aggressive counting of discrete violations may have been owed in part to the footnote describing how UBS apparently refused to disclose the name of the client at issue.

4) The way in which the violations were counted in this action raises the possibly that, if motivated to, OFAC could or would count the accrual of...

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Civil Enforcement Information - UBS AG

TURBOFAC Commentary (300 words)