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Which is itself a weird phrasing. OFAC compliance is an obligation, not an "opportunity".


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Is this essentially admission of non-adherence to OFAC requirements?

I think it is a facetious statement to reflect how difficult meeting the regulatory requirement would be.

I don't see "compliant" in that sentence.

I think you're misreading the statement - he's implying that what they actually already do is in compliance.

Of course, but OP's point was that compliance is meaningless...

>The "we didn't have to" is a little jarring given the scale of this.

How come? I interpreted it to mean that no regulations required this, but they chose to anyway. Which is true.


Right, that would be non-compliance as the OP already pointed out.

This makes it sound like complying is supposed to be a good thing. That’s an unfounded assumption imho.

> Does OFAC have the power to say "we are designating the Hawala system"?

Probably not because "Hawala system" is not an entity that can be defined - it's like banning "cryptocurrencies" in general. OFAC wouldn't be able to do that - because it's not a specific definable entity. Designating a specific hawaladar would be possible for them (though likely not very effective).


I don’t think that’s a fair take nor does it really disprove mine.

The compliance regime at big corps is definitely more sophisticated than at a player like OAI


> Easy peasy.

All these sort of regulations tend to have language disallowing actions made just to avoid the requirement (see, for example, "structuring")


That's not the consensus and "minimal" compliance is not a thing.

It seems to be a mandated requirement, as opposed to some subjective UI decision. The bigger deal is that it may indicate they don't have a good enough process to check/track these federal requirements.

That's a different type of ambiguity. That's ambiguity in the wording. The bureaucrat in question is saying they'll make the next thing illegal straight away, not that they need to go fix their poor wording.

This is a bit of weak spin on the obvious news that they probably couldn't comply with the government requirements.

It's almost definitely a violation of the CFAA.

Because there's a huge difference between being "blatantly non-compliant" vs "properly compliant".

Please explain why this isn’t compliant?

> (c) The prohibitions in subsections (a)–(b) of this section apply [...] notwithstanding any contract entered into or any license or permit granted prior to the effective date of this order.

Page 1 of https://www.treasury.gov/resource-center/sanctions/Programs/...

Kinda seems like there's no excuse for going about it this way.

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