The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Finding of Violation to MasterCard on March 16 for failing to report accounts in which blocked entities held interest. The Finding of Violation represents a rare instance of enforcement of the Reporting, Procedures, and Penalties Regulations (RPPR). Although MasterCard had restricted the accounts in which Bank Melli and Bank Saderat held interests, pursuant to restrictions on the export of services to Iran, OFAC determined that MasterCard did not take appropriate action to block the accounts completely when the two entities were subsequently added to the List of Specially Designated Nationals and Blocked Persons (SDN List). The action demonstrates the US government’s interest in access to blocked funds and the importance of a thorough compliance program. To read more about OFAC’s enforcement action against MasterCard and its potential implications, click here.