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0 pointsfennecfoxen5y ago0 comments

So look at (one one hand) a customer worth... well, PureLabs is "10 incredible FTEs," let's give them the $21/user/mo Enterprise plan at $210/month in revenue.

On the other hand, a sanctions violation could be a $65,000 fine (Trading with the Enemy Act) or $250,000 (International Emergency Economic Powers Act) for each offense. (I leave aside the million-dollar narcotics-kingpin act). On top of this we also see the risk of criminal prosecution.

In what world is it reasonable to expect anyone to take this chance?

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A4ET8a8uTh05y ago

It is hard to discuss hypothetical violations so I won't do that. It absolutely is a safe course of action to do a blanket ban. That said, is it reasonable to assume violation based on IP address ( and that is what seems to have happened here )? Banks don't automatically (typically ) block MUHAMMAD JIHAD even if they may end up questioning it.

harperlee5y ago

That’s because the combined business of all Muhammads and their employers is way more than 210$/month AND it would be illegal, and Bad PR™, to ban them from your business based just on their culture/name. Otherwise they would have been “derisked” out of service.

A4ET8a8uTh05y ago

You have a point ( and Mnuchin to his credit ,based on reports, does care about regulatory burden and its impact ). So you are right, one is not like the other. To address your point directly, if OFAC tomorrow added MOHAMMAD JIHAD with no other information ( no DOB, no address, and so on ), you would be surprised how quickly the banks would respond.

Now note that that we are discussing a name, a commmon, but somewhat reliable, if mutable, driver of our identity. Now compare it to IP address and tell me, which one is a better predictor of who you are.

Unless, we are assuming IP is a proxy for location, which is another story.

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saagarjha5y ago

> It absolutely is a safe course of action to do a blanket ban.

Except when you make a mistake and ruin someone’s morning.

slaymaker19075y ago

They do actually flag payments if you put the word Isis or something in the memo.

lawnchair_larry5y ago

Do you have a story about this?

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0 pointsfennecfoxen5y ago0 comments

So look at (one one hand) a customer worth... well, PureLabs is "10 incredible FTEs," let's give them the $21/user/mo Enterprise plan at $210/month in revenue.

In what world is it reasonable to expect anyone to take this chance?

0 comments

A4ET8a8uTh05y ago

harperlee5y ago

A4ET8a8uTh05y ago

Unless, we are assuming IP is a proxy for location, which is another story.

1 more reply

saagarjha5y ago

> It absolutely is a safe course of action to do a blanket ban.

Except when you make a mistake and ruin someone’s morning.

slaymaker19075y ago

They do actually flag payments if you put the word Isis or something in the memo.

lawnchair_larry5y ago

Do you have a story about this?

1 more reply

j / k navigate · click thread line to collapse