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Exception Tracking Spreadsheet (TicklerTrax™)
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MoneyGram and SAP settle with OFAC

OFAC has announced settlements with MoneyGram and SAP SE:

  • MoneyGram Payment Systems, Inc., a global payments company based in Dallas, Texas, that allows people to send money in more than 200 countries and territories, agreed to remit $34,328.78 to settle its potential civil liability for 359 apparent violations of multiple sanctions programs. MoneyGram provided services to blocked individuals incarcerated in U.S. federal prisons without a license from OFAC, processed transactions on behalf of an additional blocked person, and processed transactions for individuals who initiated commercial transactions involving Syria.
  • SAP SE, a software company located in Walldorf, Germany, has agreed to settle its potential civil liability for 190 apparent violations of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560, by remitting $2,132,174 to OFAC. Between approximately 2013 and 2018, SAP engaged in the export, re-export, sale, or supply of technology or services from the United States to companies in third countries with knowledge or reason to know the software or services were intended specifically for Iran, and sold cloud-based software subscription services accessed remotely through SAP’s cloud businesses in the United States to customers that made the services available to their employees in Iran. OFAC determined that SAP voluntarily self-disclosed the apparent violations, and that these apparent violations constitute a non-egregious case.
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