Enforcement Release: TradeStation Securities, Inc.

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (159 words)

Notes:

1) Compare Enforcement Release: Interactive Brokers LLC (very similar facts), and comments thereto. The description of the facts resulting in the violations is unusual insofar as it relates to a technical breakdown in the U.S. person's compliance software systems in a context where there was a good faith effort to comply in a manner that was at least intended to be sophisticated. It is likely that the reason for OFAC pursuing an enforcement action in this context, rather than a cautionary letter, is the amount of time that elapsed before the compliance breakdown was caught. In that regard, this could be viewed as one of the few (possibly the only) pure "failure to test" enforcement action. Another key factor is that TradeStation "knew or should have known about the importance of testing its systems because TradeStation received a Cautionary Letter from OFAC earlier...

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Enforcement Release: TradeStation Securities, Inc.

TURBOFAC Commentary (159 words)