3 ms·

So look at (one one hand) a customer worth... well, PureLabs is "10 incredible FTEs," let's give them the $21/user/mo Enterprise plan at $210/month in revenue.

So look at (one one hand) a customer worth... well, PureLabs is "10 incredible FTEs," let's give them the $21/user/mo Enterprise plan at $210/month in revenue. On the other hand, a sanctions violation could be a $65,000 fine (Trading with the Enemy Act) or $250,000 (International Emergency Economic Powers Act) for each offense. (I leave aside the million-dollar narcotics-kingpin act). On top of this we also see the risk of criminal prosecution. In what world is it reasonable to expect anyone to take this chance?

A4ET8a8uTh0 6y ago
It is hard to discuss hypothetical violations so I won't do that. It absolutely is a safe course of action to do a blanket ban. That said, is it reasonable to assume violation based on IP address ( and that is what seems to have happened here )? Banks don't automatically (typically ) block MUHAMMAD JIHAD even if they may end up questioning it.
- harperlee 6y ago
  That’s because the combined business of all Muhammads and their employers is way more than 210$/month AND it would be illegal, and Bad PR™, to ban them from your business based just on their culture/name. Otherwise they would have been “derisked” out of service.
  - A4ET8a8uTh0 6y ago
    You have a point ( and Mnuchin to his credit ,based on reports, does care about regulatory burden and its impact ). So you are right, one is not like the other. To address your point directly, if OFAC tomorrow added MOHAMMAD JIHAD with no other information ( no DOB, no address, and so on ), you would be surprised how quickly the banks would respond. Now note that that we are discussing a name, a commmon, but somewhat reliable, if mutable, driver of our identity. Now compare it to IP address and tell me, which one is a better predictor of who you are. Unless, we are assuming IP is a proxy for location, which is another story.
    - harperlee 6y ago
      Banks typically would react overnight to OFAC list updates, through a sanctions list service. If no DOB or similar is also provided, though, scoring should not be too high - and if a match with Mohammad is enough to trigger an alert, the overnight alert delta would be either manually processed by Compliance, or bulk closed as false positives, depending on how much time you need to unblock the clients and similar risk considerations.
      - A4ET8a8uTh0 6y ago
        I am not sure if you realize it, but you are proving my point. Banks found a way to address the issue without adversely affecting the customers. Github appears to have only recently started to do the same, but they opted for a blanket approach as opposed to a more targeted one.
        harperlee 6y ago
        Sure, I’m just not trying to disprove you, I argued similarly in other threads.
- saagarjha 6y ago
  > It absolutely is a safe course of action to do a blanket ban. Except when you make a mistake and ruin someone’s morning.
- slaymaker1907 6y ago
  They do actually flag payments if you put the word Isis or something in the memo.
  - lawnchair_larry 6y ago
    Do you have a story about this?
    - zinekeller 6y ago
      Not parent and not about terrorism directly, but Tardigrade Ltd. was sanctioned in US (because it is an arms dealer without licence in US) causing all "Tardigrade" payments blocked (even innocuous ones): https://news.ycombinator.com/item?id=24450828 https://news.ycombinator.com/item?id=24450828

A4ET8a8uTh0 6y ago

It is hard to discuss hypothetical violations so I won't do that. It absolutely is a safe course of action to do a blanket ban. That said, is it reasonable to assume violation based on IP address ( and that is what seems to have happened here )? Banks don't automatically (typically ) block MUHAMMAD JIHAD even if they may end up questioning it.

harperlee 6y ago
That’s because the combined business of all Muhammads and their employers is way more than 210$/month AND it would be illegal, and Bad PR™, to ban them from your business based just on their culture/name. Otherwise they would have been “derisked” out of service.
- A4ET8a8uTh0 6y ago
  You have a point ( and Mnuchin to his credit ,based on reports, does care about regulatory burden and its impact ). So you are right, one is not like the other. To address your point directly, if OFAC tomorrow added MOHAMMAD JIHAD with no other information ( no DOB, no address, and so on ), you would be surprised how quickly the banks would respond. Now note that that we are discussing a name, a commmon, but somewhat reliable, if mutable, driver of our identity. Now compare it to IP address and tell me, which one is a better predictor of who you are. Unless, we are assuming IP is a proxy for location, which is another story.
  - harperlee 6y ago
    Banks typically would react overnight to OFAC list updates, through a sanctions list service. If no DOB or similar is also provided, though, scoring should not be too high - and if a match with Mohammad is enough to trigger an alert, the overnight alert delta would be either manually processed by Compliance, or bulk closed as false positives, depending on how much time you need to unblock the clients and similar risk considerations.
    - A4ET8a8uTh0 6y ago
      I am not sure if you realize it, but you are proving my point. Banks found a way to address the issue without adversely affecting the customers. Github appears to have only recently started to do the same, but they opted for a blanket approach as opposed to a more targeted one.
      - harperlee 6y ago
        Sure, I’m just not trying to disprove you, I argued similarly in other threads.
saagarjha 6y ago
> It absolutely is a safe course of action to do a blanket ban. Except when you make a mistake and ruin someone’s morning.
slaymaker1907 6y ago
They do actually flag payments if you put the word Isis or something in the memo.
- lawnchair_larry 6y ago
  Do you have a story about this?
  - zinekeller 6y ago
    Not parent and not about terrorism directly, but Tardigrade Ltd. was sanctioned in US (because it is an arms dealer without licence in US) causing all "Tardigrade" payments blocked (even innocuous ones): https://news.ycombinator.com/item?id=24450828 https://news.ycombinator.com/item?id=24450828