OFAC has issued a Finding of Violation to MasterCard for failing to report that it held bank accounts in which two Iranian banks, Bank Melli and Bank Saderat, had an interest during a period in which they were subject to US sanctions. Although it failed to report that it held the accounts when the banks were designated, MasterCard had previously taken steps to place restrictions on the accounts following the introduction of new US sanctions on Iran in 1995.
In its enforcement notice, OFAC states that while no MasterCard personnel appear to have had actual knowledge of the conduct that led to the violations, MasterCard had reason to know that it maintained funds associated with sanctioned entities, and as a large and commercially sophisticated company that deals primarily with banks and other financial institutions should have identified and reported the accounts and related property, even though they had become dormant.
Michael was called to the Bar in 1992 and prior to joining Peters & Peters was a senior specialist prosecutor at the Crown Prosecution Service Headquarters (CPS). He was a key member of a small specialist unit responsible for the prosecution of serious and high-profile fraud, terrorist,...See profile for Michael O'Kane >