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November 19, 2018 SanctionsAlert.com Sanctions Round Up

US Imposes Sanctionson 17 Saudis for Alleged Role in Khashoggi Killing, but Prince Stays Clear

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OFAC $5M Fine Against JPMC Partially Due To Failure in Properly Screening Clients’ Pooling Accounts

October 29, 2018 By: Scott Nance*

In order to optimize interest and improve liquidity for their clients, financial institutions frequently maintain so-called ‘pooling accounts’, in which funds from many different accounts are combined. Funds in such accounts may belong to multiple persons or belong to only one person, but are often used to make payments to a number of other parties on a periodic basis. Pooled accounts are often used to settle balances between these different entities.

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OFAC Fines Epsilon $1.5 Million: Four Lessons for U.S. Exporters With Products In Iran

October 3, 2018 By: SanctionsAlert.com

On September 13, 2018, Epsilon Electronics Inc, a car audio and video equipment manufacturer, agreed to pay the U.S. Treasury’s Office of Foreign Assets Control (OFAC) $1,500,000 to settle a case related to alleged violations of the Iranian Transactions and Sanctions Regulations.

The case, which is a culmination of a 2014 penalty notice and two court cases, contains four vital lessons for U.S. exporters whose products may be found in Iran.

The September 2018 settlement is a re-consideration of a disputed penalty notice from 2014, at which time OFAC fined Epsilon $4,000,000. In the 2014 notice, OFAC alleges that from 2008 to 2012, the electronics manufacturer broke the law by selling audio and video equipment to Asra International, LLC. (more…)

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