The National Australia Bank informed OFAC that in transactions involving at least one Cuban national, the bank transfered money through New York City.
In response, the agency slapped the golden swimmers from down under with a 100,000 dollar fine, 10% of what OFAC claims they could have hit them with.
It’d be nice to get some details on this. But surely someone in the bank’s IT department must have had a re-routing headache, providing the bank still wants to do business with Cubans, which seems like a fair question for the bank’s PR people.
I trust Australia has some laws against discriminating on the basis of Nationality and, if even re-routing the Cubans costs them some money, the bank could find itself between a rock and hard place. Time being money, sort of thing, or so they tell me.
But, for OFAC, the spectacle gives them a chance to put all banks on notice that data flowing across the United States is subject to their jurisdiction. And there’s a whole lot of money transfered through New York City, in a minute.
Compliance officers, you’ve been warned.
http://www.treasury.gov/offices/enforcement/ofac/actions/20070911.shtml
(say, is there an election in Florida soon?)