Enforcement Release - Tango Card, Inc.

Date issued: Sep. 30 2022

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TURBOFAC Commentary (338 words)

Notes:

1) This appears to be the first enforcement action related to "stored value cards" since the 2008 Voipescrow Inc. (Iran) case. The legal basis for the violations is straightforward, with "services" having been exported to the sanctioned jurisdictions no different than they would have been deemed to have been exported if Tango Card were an ordinary payment processor.

2) TLD ASSOCIATED WITH EMAIL ADDRESSES AS A "REASON TO KNOW" OR "IN OR ORDINARILY RESIDENT IN" STATUS?

OFAC has, on several occasions, made it relatively clear that when an person receives internet services using an IP address associated with a sanctioned destination, that person is presumed to be in or ordinarily resident in the destination. Refer generally to General Note on the "Ordinarily Resident" Test for IEEPA-Based...