I just published an article on KYC360 (aka RiskScreen) about the Finding of Violation that OFAC issued to Aero Sky. I don’t take issue with the fact that the violation occurred or that a Finding of Violation was appropriate in the current environment (the company has since been dissolved) – but I take issue with OFAC’s statement that a “strong” civil monetary penalty would have been issued if the company was still in business.
Yes, there’s a typo (I repeated the same phrase twice – hopefully it’s been removed online by the time you read this) – but I’d be curious as to what you think of it.
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