I noticed something odd in the May installment of OFAC's monthly enforcement update. Normally, each enforcement action ends with a statement that indicates whether or not the violation was voluntarily disclosed to OFAC. A violation that was not voluntarily disclosed normally reads as follows:
[Company Name] did not voluntarily disclose this matter to OFAC.
However, this month there was a case involving Fleet National Bank and Suretrade and it concluded with this statement:
This matter was not the subject of a voluntary disclosure to OFAC.
Is this an intentional distinction? And if so, what the heck does it mean?
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I think it may be that the "not the subject of" a voluntary disclosure suggests that a voluntary disclosure was made about other things and that in the course of reviewing those things, OFAC discovered other violations. Just a guess.
It could also just be "special agent" speak which always adds unnecessary verbiage. For example, the perp doesn't just "make a wire transfer to Iran" but instead "makes and causes a fund transfer aka a wire transfer of what were believed to be funds and which were destined to a recipient in Iran."
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