Enforcement Release - MoneyGram Payment Systems, Inc.

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 (467 words)

Notes:

1) With a few exceptions discussed below, there the MoneyGram case is similar to other enforcement actions against remittance industry participants. Compare Western Union Financial Services, Inc.. The legal bases for the penalty are straightforward.

As it relates to payments made to or behalf of blocked persons, U.S. person payment remitters violate sanctions regulations when they process payments in which a blocked person has an “interest”. Here, OFAC notes that a number of violations arose from payments made to blocked prisoners held in U.S. facilitates. A prisoner held in the U.S. is necessarily a “U.S. person” for the purposes of sanctions regulations, and this is the case even with respect to foreign nationals that are only in the U.S. because they have been extradited or were arrested upon arrival and subsequently held in the U.S. against their will. Compare

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Enforcement Release - MoneyGram Payment Systems, Inc.

TURBOFAC Commentary (467 words)