W.M.D. [proliferation] Sanctions breach and enforcement action
24/07/2022
OFAC just issued a violation to MidFirst Bank https://www.midfirst.com/ for transactions it did with an S.D.N. within SIX HOURS of the designation.
The OFAC action is the first enforcement case in OFAC history where:
- OFAC points to the specific time between when a name went on a list and
- When the violator was engaged in the transaction.
What exactly happened? Link to action and original sanctions in comments.
- MidFirst processed
- Five transactions totalling $604,000 on behalf of accounts held by the blocked persons.
- Two of those transactions, totalling $400,000, were internal book transfers between one of the blocked person's accounts at MidFirst.
- On September 21, 2020,
- At 12:36 p.m. EDT,
- OFAC designated two individuals to the S.D.N. List ("the blocked persons") according to the WMDPSR.
- Between 2:00 p.m. EDT and 5:48 p.m. EDT,
- MidFirst processed five transactions totalling $604,000 on behalf of accounts held by the blocked persons.
- Between September 22, 2020, and October 5, 2020,
- MidFirst processed 29 additional transactions totalling $9,879.02 on behalf of the blocked persons.
- Ninety-eight per cent of the post-designation transactions value occurred within six hours of designation.
- At 12:36 p.m. EDT,
Who are the S.D.N.s, and why a bank in Oklahoma was doing business with S.D.N.s,
- Oklahoma has a large energy industry, and
- The two entities added that day were MAMMUT DIESEL and MAMMUT INDUSTRIAL GROUP P.J.S.
SOURCE
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220721
https://home.treasury.gov/system/files/126/20220721_midfirst.pdf
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