Published today on KYC360, Amazon: Prime Time for Penalties is my latest. It goes beyond the facial failures and tries to dig a little deeper – like, why did they not catch references to Yalta? Did they not have geographic place name data? Was the reference in a data element they weren’t screening?
And more importantly, why wasn’t this uncovered over almost 7 years? Too bad they didn’t have the Framework document back then, huh?
Hope you like it – comments welcome, of course. And thanks to my editor, Brian Orsak, who turned this around in less than a day after I submitted it to him.
Of course, I will add a PDF to my Publications page.
Categories: Civil Monetary Penalties Enforcement Actions North Korea (DPRK) Sanctions OFAC Updates Published Articles
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