On 29 April, OFAC announced that it had agreed a settlement with MoneyGram Payment Systems Inc, the global payments company based in Dallas, Texas.  MoneyGram agreed to remit $34,328.78 to settle its potential civil liability for 359 apparent violations of multiple sanctions programmes.  it provided services to blocked individuals incarcerated in US federal prisons without a licence from OFAC, processed transactions on behalf of an additional blocked person, and processed transactions for individuals who initiated commercial transactions involving Syria. OFAC says that MoneyGram’s apparent violations were voluntarily self-disclosed and were non-egregious.

A separate agreement with SAP SE, a software company located in Walldorf, Germany, which has agreed to settle its potential civil liability for 190 apparent violations of the Iranian Transactions and Sanctions Regulations.  SAP engaged in the export, re-export, sale, or supply of technology or services from the US to companies in third countries with knowledge or reason to know the software or services were intended specifically for Iran, and sold cloud-based software subscription services accessed remotely through SAP’s cloud businesses in the US to customers that made the services available to their employees in Iran.  This agreement followed a self-disclosure by SAP.



Any modest contributions for my time and ongoing expenses are welcomed!  I have a page, where contributions start as low as $3, at https://www.buymeacoffee.com/KoIvM842y

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s