Civil Enforcement Information - JPMorgan Chase Bank N.A. (1st violation)

Date issued: Aug. 25 2011

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TURBOFAC Commentary (321 words)

Notes:

*For further factual information refer to Settlement Agreement - JPMorgan Chase Bank N.A. (1st violation).

1) Provisions violated pulled from Settlement Agreement.

2) Rare case in which penalties brought in part for rejecting, rather than blocking funds.

3) Processing transactions involving blocked vessels, e.g. when goods are shipped on blocked vessels, constitutes dealing in property in which a blocked person has an interest irrespective of the owner of the vessel (para 7., Settlement Agreement).

4) One penalty was based on JPMC making a "trade loan to the bank issuer of a letter of credit in which the underlying transaction involved a vessel that had been identified as blocked pursuant to the WMDPSR due to its affiliation with the Islamic...