Enforcement Release: State Street Bank and Trust Company

Date issued: Jun. 26 2024

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (873 words)

Consolidated Comment on Enforcement Release: State Street Bank and Trust Company and Settlement Agreement (OFAC) - State Street Bank and Trust Company

1) "DEALING IN" NEW DEBT - COUNTING VIOLATIONS

From a legal basis standpoint, and even from a factual standpoint in many respects, this case is very similar to Enforcement Release - S&P Global, Inc., which also involved a sophisticated financial service-adjacent entity reissuing and re-dating invoices issued to SSI entities and accepting past-due payments. There, as here, each reissuance/re-dating and acceptance of payment was regarded as a separate violation. Note that, consistent with other cases, instances of prohibited payments being rejected by U.S. banks were not counted as "attempted" violation on the part of the U.S. person would-be recipient of the funds.

Notably, however, in this case OFAC determined the violations to be...