Enforcement Release - S&P Global, Inc.

Date issued: Apr. 01 2022

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TURBOFAC Commentary (1184 words)

Notes:

[7-28-24 update - see Enforcement Release: State Street Bank and Trust Company (very similar case), and note that the below has not yet been amended to reflect the issuance of the State Street enforcement release]

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1) The S&P Global case is the second enforcement action focused on SSI Directive 2 (after Haverly Systems, Inc.), and the third enforcement action related to the 2014 Ukraine-related SSI directives (see also Civil Enforcement Information - Cameron International Corporation).

2) Reissued Invoices as a "Dealing" in Prior Post-sanctions "New Debt"

Factually, the case is similar to Haverly Systems, Inc., but there are a few notable differences. The primary difference is that, here, there were apparent attempts to game (if not "evade") the “new debt” prohibitions by reissuing invoices connected to pre-existing,...