Archives: Sanctions Enforcement

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OFAC Finding of Sanctions Violation Prompts Guidance on “False Hit Lists”

On October 21, 2015, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a Finding of Violation against BMO Harris Bank as the successor to Marshall and Ilsley Bank, which originated over $67,000 in funds transfers in 2011 on behalf of an entity involved in importing Iranian-origin carpets.  The bank had previously processed … Continue Reading