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> US federal law, of which Microsoft must follow as a US company. One interesting and under-appreciated fact about OFAC: they take an, ahem, expansive view of
by bad416f1f5a2 4y ago
> US federal law, of which Microsoft must follow as a US company.
One interesting and under-appreciated fact about OFAC: they take an, ahem, expansive view of where US law applies.
CSE TransTel was a company based in Singapore who was sanctioned in 2017[0]. They had a bank account with a Singapore bank. TransTel did business with Iran, in violation of US sanctions. But neither the company nor the bank were in the US; how did OFAC make that fly?
Because TransTel did transactions with a US dollar account, OFAC argued the settlements of that account caused banks inside the US to incidentally violate sanctions. Essentially the presence of US dollars created a nexus and allowed OFAC to enforce US sanctions against what would appear to be an entirely foreign entity.
Any wonder MS is treading lightly?
[0]: https://home.treasury.gov/system/files/126/20170727_transtel.pdf https://home.treasury.gov/system/files/126/20170727_transtel...