Tag Archives: Lee International IP & Law Group

ILN Today Post

New Liability to U.S. Government for U.S. Dollar Transactions Made with Companies in U.S.-Sanctioned Countries

On July 27, 2017, the US Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it had entered into a USD $12 million settlement with several companies located in Singapore, based on payments that those companies made to various vendor companies in Iran in connection with some telecommunications projects. The payments to the Iranians were made in U.S. dollars (USD) in a series of 104 USD wire transfers totaling approximately $11 million.  The wire transfers were initiated from a non-U.S. bank in Singapore, but all the fund transfers were processed through U.S. banks.  None of the transfer documents prepared by the Singapore companies made reference to Iran or Iranian parties. The Singapore companies previously had committed to their Singapore bank that they would not route any transactions related to Iran through the bank.

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