• Re: Bank transaction blocked as it may "violate international sanctions

    From Jeff Gaines@21:1/5 to J Newman on Fri Dec 27 14:00:57 2024
    On 27/12/2024 in message <vkm3cc$3j1dg$1@dont-email.me> J Newman wrote:

    2. How did they go ballistic over just a name match and a thousand quid?

    3. Should my friend get upset over the implied allegations that her
    business is involved in international sanctions evasion?

    Whatever a bank may tell you its only interest is protecting itself. I
    don't know what the penalty is for sanction busting but this bank clearly
    has no plans to find out.

    --
    Jeff Gaines Dorset UK
    Here we go it's getting close, now it's just who wants it most.

    --- SoupGate-Win32 v1.05
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  • From Jethro_uk@21:1/5 to J Newman on Fri Dec 27 15:32:06 2024
    On Fri, 27 Dec 2024 15:34:33 +0400, J Newman wrote:

    Can bona fide businesses become guilty by unwitting association with
    people involved in international sanctions laws?

    https://en.wikipedia.org/wiki/Arms-to-Iraq_affair

    --- SoupGate-Win32 v1.05
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  • From Roger Hayter@21:1/5 to Jeff Gaines on Fri Dec 27 16:08:46 2024
    On 27 Dec 2024 at 14:00:57 GMT, ""Jeff Gaines"" <jgnewsid@outlook.com> wrote:

    On 27/12/2024 in message <vkm3cc$3j1dg$1@dont-email.me> J Newman wrote:

    2. How did they go ballistic over just a name match and a thousand quid?

    3. Should my friend get upset over the implied allegations that her
    business is involved in international sanctions evasion?

    Whatever a bank may tell you its only interest is protecting itself. I
    don't know what the penalty is for sanction busting but this bank clearly
    has no plans to find out.

    Didn't the US fine Barclays several billion pounds for allegedly breaking sanctions? Mind you they may be simply using these fines to reduce competition against their banks, but you can't blame the banks for being careful.

    --

    Roger Hayter

    --- SoupGate-Win32 v1.05
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  • From Andy Burns@21:1/5 to J Newman on Fri Dec 27 17:01:07 2024
    J Newman wrote:

    How did they go ballistic over just a name match and a thousand quid?
    The potential penalty is sufficient to get their attention?

    <https://www.gov.uk/government/publications/financial-sanctions-enforcement-and-monetary-penalties-guidance/financial-sanctions-enforcement-and-monetary-penalties-guidance#powers-given-to-hm-treasury-to-impose-penalties-for-financial-sanctions-breaches>

    --- SoupGate-Win32 v1.05
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  • From GB@21:1/5 to J Newman on Fri Dec 27 17:28:01 2024
    On 27/12/2024 11:34, J Newman wrote:
    A friend of mine who does various business/web development & marketing
    gigs for online clients (usually varying in quantity from £10 - £1000)
    got this message from her bank.

    "We've suspended transfer 1234567890 reference "XYZ REMITTANCE" for a sanctions review as it may potentially violate international sanctions
    laws."


    They asked for more details about who XYZ is, where they are located and
    what the transfer is for.

    At first she ignored the message because it sounded like a phishing
    attempt, but upon further scrutiny she saw that it did indeed come from
    her bank, and the client who was paying her said they had already done
    so. So she answered their questions.

    It seems like the client's name XYZ matched a red flagged entity and the
    sum of a few thousand quid is clearly up there in sums involved for international sanctions evaders to buy their ICBMs.

    I had a number of questions:
    1. Surely my friend's bank could have seen where the money came from and
    that the origin financial institution & country also complies with
    sanctions laws?

    2. How did they go ballistic over just a name match and a thousand quid?

    The bank is given a list of sanctioned people. They are just doing what
    they are required to do. There may be a de minimis limit that nobody
    worries about, but evidently the sum involved exceeds it in this case.



    3. Should my friend get upset over the implied allegations that her
    business is involved in international sanctions evasion?

    No. There is no allegation, just an enquiry. And, bearing in mind your
    point 5 below, your friend *may* have broken the law.




    4. It didn't cause damage because delays in receiving a thousand quid
    for a self-employed person isn't so bad. But if it is an established
    company with payrolls and other time-critical obligations, could someone whose transactions were blocked sue the financial institution for
    damages? Or would the bank just claim that it was due diligence
    processes that needed to run their course?

    Yes, it's due diligence.


    5. There is only so much due diligence my friend can do on potential
    clients. Can bona fide businesses become guilty by unwitting association
    with people involved in international sanctions laws?

    Absolutely, she could theoretically be in big trouble. I haven't heard
    of lots of prosecutions, though.

    Hopefully, she's in the business of designing knitting patterns, say,
    rather than missile guidance software.

    --- SoupGate-Win32 v1.05
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  • From Pamela@21:1/5 to Roger Hayter on Fri Dec 27 23:22:03 2024
    On 16:08 27 Dec 2024, Roger Hayter said:
    On 27 Dec 2024 at 14:00:57 GMT, ""Jeff Gaines"" <jgnewsid@outlook.com>
    wrote:
    On 27/12/2024 in message <vkm3cc$3j1dg$1@dont-email.me> J Newman
    wrote:

    2. How did they go ballistic over just a name match and a thousand
    quid?

    3. Should my friend get upset over the implied allegations that her
    business is involved in international sanctions evasion?

    Whatever a bank may tell you its only interest is protecting itself.
    I don't know what the penalty is for sanction busting but this bank
    clearly has no plans to find out.

    Didn't the US fine Barclays several billion pounds for allegedly
    breaking sanctions? Mind you they may be simply using these fines to
    reduce competition against their banks, but you can't blame the banks
    for being careful.

    Standard Chartered (and Deutsche Bank) also got into serious scrapes with
    US authorities for sanctions busting and money laundering.

    Some banks in the City are said to sail close to the wind which has helped
    it acquire the nickname of "London laundromat".

    --- SoupGate-Win32 v1.05
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  • From billy bookcase@21:1/5 to J Newman on Sat Dec 28 10:18:52 2024
    "J Newman" <jenniferkatenewman@gmail.com> wrote in message news:vko5ep$695j$1@dont-email.me...

    No way, that customer in question needed help setting up a website for online counseling sessions including a payment portal. Hardly "interesting" stuff.

    Whereas ne'er do wells, of whatever pursuasion, might not also be in need of some "online counselling" ?


    bb

    --- SoupGate-Win32 v1.05
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  • From billy bookcase@21:1/5 to J Newman on Sat Dec 28 13:00:26 2024
    "J Newman" <jenniferkatenewman@gmail.com> wrote in message news:vkol27$9hh8$1@dont-email.me...
    On 28/12/2024 14:18, billy bookcase wrote:
    "J Newman" <jenniferkatenewman@gmail.com> wrote in message
    news:vko5ep$695j$1@dont-email.me...

    No way, that customer in question needed help setting up a website for online
    counseling sessions including a payment portal. Hardly "interesting" stuff. >>
    Whereas ne'er do wells, of whatever pursuasion, might not also be in need of >> some "online counselling" ?


    bb


    Surely you cannot be suggesting that someone who sets up an e-commerce website for a
    counselor is responsible for the clients they counsel?

    It's the kind of counselling which might be on offer, which is the point.

    More especially if its being offered by superficially benign, religious or political extremists.

    A bit of a step up from knitting patterns, IOW.



    bb

    --- SoupGate-Win32 v1.05
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  • From Jon Ribbens@21:1/5 to J Newman on Sat Dec 28 13:32:47 2024
    On 2024-12-28, J Newman <jenniferkatenewman@gmail.com> wrote:
    On 28/12/2024 14:18, billy bookcase wrote:
    "J Newman" <jenniferkatenewman@gmail.com> wrote in message
    news:vko5ep$695j$1@dont-email.me...
    No way, that customer in question needed help setting up a website
    for online counseling sessions including a payment portal. Hardly
    "interesting" stuff.

    Whereas ne'er do wells, of whatever pursuasion, might not also be in
    need of some "online counselling" ?

    Surely you cannot be suggesting that someone who sets up an e-commerce website for a counselor is responsible for the clients they counsel?

    I wouldn't be surprised if terrorism legislation in theory makes
    a counsellor potentially legally criminally liable if it turns out
    one of their clients was a terrorist, regardless of whether they
    knew or even could have known that they were.

    --- SoupGate-Win32 v1.05
    * Origin: fsxNet Usenet Gateway (21:1/5)
  • From GB@21:1/5 to Jon Ribbens on Sun Dec 29 11:21:28 2024
    On 28/12/2024 13:32, Jon Ribbens wrote:
    On 2024-12-28, J Newman <jenniferkatenewman@gmail.com> wrote:
    On 28/12/2024 14:18, billy bookcase wrote:
    "J Newman" <jenniferkatenewman@gmail.com> wrote in message
    news:vko5ep$695j$1@dont-email.me...
    No way, that customer in question needed help setting up a website
    for online counseling sessions including a payment portal. Hardly
    "interesting" stuff.

    Whereas ne'er do wells, of whatever pursuasion, might not also be in
    need of some "online counselling" ?

    Surely you cannot be suggesting that someone who sets up an e-commerce
    website for a counselor is responsible for the clients they counsel?

    I wouldn't be surprised if terrorism legislation in theory makes
    a counsellor potentially legally criminally liable if it turns out
    one of their clients was a terrorist, regardless of whether they
    knew or even could have known that they were.


    We're going off into la-la land here, but theoretically the counsellor
    could be helping to patch up troops with PTSD, so that they can be sent
    back to the front line.

    Anyway, hopefully, the OP can see why it might not be entirely obvious
    to the bank, and why the OP's friend should not take too much umbrage
    over this.

    --- SoupGate-Win32 v1.05
    * Origin: fsxNet Usenet Gateway (21:1/5)
  • From Jethro_uk@21:1/5 to Jon Ribbens on Sun Dec 29 11:53:31 2024
    On Sat, 28 Dec 2024 13:32:47 +0000, Jon Ribbens wrote:

    On 2024-12-28, J Newman <jenniferkatenewman@gmail.com> wrote:
    On 28/12/2024 14:18, billy bookcase wrote:
    "J Newman" <jenniferkatenewman@gmail.com> wrote in message
    news:vko5ep$695j$1@dont-email.me...
    No way, that customer in question needed help setting up a website
    for online counseling sessions including a payment portal. Hardly
    "interesting" stuff.

    Whereas ne'er do wells, of whatever pursuasion, might not also be in
    need of some "online counselling" ?

    Surely you cannot be suggesting that someone who sets up an e-commerce
    website for a counselor is responsible for the clients they counsel?

    I wouldn't be surprised if terrorism legislation in theory makes a
    counsellor potentially legally criminally liable if it turns out one of
    their clients was a terrorist, regardless of whether they knew or even
    could have known that they were.

    Isn't there already an obligation on counsellors, therapists and all the
    other potential recipients of inside knowledge to report anything *they
    regard as credible* to "the authorities" ? Certainly there is no real
    concept of privileged communication in English law. No matter what people
    think should happen we know that judges rarely exclude unlawful evidence.

    For some reason the US case around Samuel Mudd springs to mind. (I could
    bask in the fact that knowing that makes me sound like a devout student
    of historical legal cases. The reality is I saw a TV movie in the 80s
    about it ...)

    --- SoupGate-Win32 v1.05
    * Origin: fsxNet Usenet Gateway (21:1/5)
  • From Jon Ribbens@21:1/5 to jethro_uk@hotmailbin.com on Sun Dec 29 14:34:43 2024
    On 2024-12-29, Jethro_uk <jethro_uk@hotmailbin.com> wrote:
    On Sat, 28 Dec 2024 13:32:47 +0000, Jon Ribbens wrote:
    On 2024-12-28, J Newman <jenniferkatenewman@gmail.com> wrote:
    On 28/12/2024 14:18, billy bookcase wrote:
    "J Newman" <jenniferkatenewman@gmail.com> wrote in message
    news:vko5ep$695j$1@dont-email.me...
    No way, that customer in question needed help setting up a website
    for online counseling sessions including a payment portal. Hardly
    "interesting" stuff.

    Whereas ne'er do wells, of whatever pursuasion, might not also be in
    need of some "online counselling" ?

    Surely you cannot be suggesting that someone who sets up an e-commerce
    website for a counselor is responsible for the clients they counsel?

    I wouldn't be surprised if terrorism legislation in theory makes a
    counsellor potentially legally criminally liable if it turns out one of
    their clients was a terrorist, regardless of whether they knew or even
    could have known that they were.

    Isn't there already an obligation on counsellors, therapists and all the other potential recipients of inside knowledge to report anything *they regard as credible* to "the authorities" ? Certainly there is no real
    concept of privileged communication in English law. No matter what people think should happen we know that judges rarely exclude unlawful evidence.

    For some reason the US case around Samuel Mudd springs to mind. (I could
    bask in the fact that knowing that makes me sound like a devout student
    of historical legal cases. The reality is I saw a TV movie in the 80s
    about it ...)

    Well certainly if a patient comes to a therapist and says "Can you help
    me with the incredible stress I'm feeling due to the terrorist atrocity
    I'm going to commit next week, in which hundreds of people will die?"
    then I expect the therapist is supposed to tell somebody. But above
    I was proposing that the patient hadn't said anything like that, and
    the therapist had no way of knowing they were a terrorist.

    --- SoupGate-Win32 v1.05
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