ILMA Compoundings – October 2019 - 23

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and their respective locations, such as customers, beneficiaries,
corresponding banks and others); (2) a description of the goods
or services that are the subject of the transaction; and (3) the
legal authority or authorities under which the transaction was
rejected. As uncomfortable as it might be, the report requires the
identity of all parties that are involved directly or indirectly in
the transaction. Similarly, the description of the goods or services
must provide sufficient detail to provide transparency concerning
the likely benefit to the parties. Citation of the legal authorities
serving as the basis for the rejection requires care, particularly from the standpoints of specificity and completeness.
The transparency required in the report can pose uncomfortable overtones that could impact one or more of the
relationships with other parties to the transaction. Potential
repercussions might not occur directly, but the process
might have a chilling effect on some of the relationships,
including those with supporting financial institutions.
The potential discomfort of this situation can be compounded by the fact that the report must be submitted within

10 days following the rejection. The complexity of gathering
and wordsmithing the report details leaves little time to
negotiate political concerns among the parties involved.
Preparedness for these reporting scenarios is paramount.
REPORTING NOT OPTIONAL
Despite the above discussion that might seem to disincentive a decision to report, I cannot emphasize enough the fact
that erring on the side of reporting, where circumstances are
unclear, is the prudent approach. Consequences attributable
to failure to report are onerous. Fines and penalties are
meaningful in and of themselves. The reputational damage
with OFAC and related agencies that can follow a mistaken
decision to remain silent are worse.
Eggenschwiler, an ILMA consultant, is an
international trade attorney and director of global
trade for the Redstone Group, a Trinity Consultants
company. He can be reached at 614-923-7472
or jeggenschwiler@redstonegrp.com.

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ILMA Compoundings – October 2019

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