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My commentary on the Aero Sky Finding of Violation

I just published an article on KYC360 (aka RiskScreen) about the Finding of Violation that OFAC issued to Aero Sky. I don’t take issue with the fact that the violation occurred or that a Finding of Violation was appropriate in the current environment (the company has since been dissolved) – but I take issue with OFAC’s statement that a “strong” civil monetary penalty would have been issued if the company was still in business.

Yes, there’s a typo (I repeated the same phrase twice – hopefully it’s been removed online by the time you read this) – but I’d be curious as to what you think of it.


OFAC’s Messaging: Grounded in Reality?

Categories: Blogs Enforcement Actions Finding of Violation General Information Iranian Sanctions OFAC Updates Published Articles Terrorism


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