Enforcement Release (FOV) - MidFirst Bank

Date issued: Jul. 21 2022

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TURBOFAC Commentary (454 words)

Notes:

1) This FOV appears aimed at signaling OFAC's expectation that FIs ensure that the lists they screen against are sufficiently up to date. We are not aware of OFAC ever having imposed a penalty based on facts such as these, where “violations” charged were based on transactions within an hour and twenty four minutes of designation.

2) The two SDNs at issue are MAMMUT DIESEL and MAMMUT INDUSTRIAL GROUP P.J.S (see https://web.archive.org/web/20230306204242/https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20200921). Note that while they are both Iranian entities, OFAC only charged violations of the WMDPSR, rather than the ITSR. An elephant in the room here is that the mere maintenance of these accounts for the entities at issue was a violation of the ITSR...