FROM A
DIFFERENT ANGLE by Kenneth Rijock
Financial Crime Consultant, for World-Check
OFAC Deletions can be Confusing
3 July 2009

For those of you who also look suspiciously at the removals from sanctions, published from time to time by the Office of Foreign Assets Control [OFAC], it might be well to remember that there can also be valid reasons why the names of entities have been deleted. Whilst it is perfectly normal to immediately believe that the offending individual has worked out some dark arrangement with the US law enforcement, that allowed him or her to keep a portion of their ill-gotten gains, there are other, more legitimate reasons for companies to come off the OFAC list. 

Look at these examples:

  •  In the latest deletion published, it was revealed that the business entities sanctioned had been seized and forfeited, meaning that they would now be sold to bona-fide purchasers. We certainly don't want the buyers to be regarded as pariahs by the business world, due to the original criminal operators.
  • If a company has been closed, due to the arrest of the owner or owners, and it ceases to exist in any form, then it is prudent to remove the name from the sanctions list if that name is deceptively similar to that of legitimate businesses, who are suffering from the intended confusion. Remember, financial criminals often deliberately utilise names that are extremely close to those of ongoing companies.
  • The company sanctioned may have been named in error, the mistake brought to the attention of OFAC, and a correction quietly made. Of course, you can imagine that this rarely occurs.

Therefore, please do not always assume some evil plea bargain has quietly taken place, permitting the criminal to keep a portion of his criminally-acquired assets. 

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The facts and opinions stated in this article are those of the author and not those of World-Check. World-Check does not warrant the accuracy of any facts and opinions stated in this article, does not endorse them, and accepts no responsibility for them.

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