Enforcement Release (FOV) - Nodus International Bank, Inc.

Date issued: Oct. 18 2022

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TURBOFAC Commentary (176 words)

Notes:

1) Compare MasterCard International Incorporated (failure to block and report credit card accounts of an SDN). As it relates to the reporting requirement component, this FOV appears aimed at stressing that "accurate reporting" is required by the RPPR, not just reporting. This appears to be the first time that OFAC has used inaccurate or inconsistent reports (otherwise filed in good faith) as a basis for finding an violation of the RPPR.

2) OFAC cites 591.202 of the VSR as the basis for the blocking regulation violations (Nodus engaged in three transactions totaling $50,271.29 in violation of § 591.202 of the VSR). 591.202 is the standard "Effect of transfers violating the provisions of this part" provision, and does not appear to have ever been cited as the...