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Last week OFAC released it’s monthly report of civil penalties. One entry bears quoting in its entirety:
One individual has agreed to a settlement totaling $485 for allegedly engaging in transactions with an entity previously identified as a Specially Designated Narcotics Trafficker (“SDNT”) violating 31 C.F.R. Part 598: OFAC alleged that from February to June 2002, the individual made payments by cash and credit card to the SDNT representing rent for space for the use of a trailer. The individual did not voluntarily disclose this matter to OFAC.
Now, perhaps there’s more here than meets the eye, but what meets the eye is a monumental waste of taxpayer resources.
Just imagine the look on the face of the trailer park tenant when he received a letter from the Department of Treasury telling him it was illegal for him to pay his rent and then imagine his phone call with OFAC.
Tenant: “An SD what?”
OFAC Agent: “An SDNT. That means Specially Designated Narcotics Trafficker.”
Tenant: “Well, how the hell was I supposed to know that?”
OFAC Agent: “There’s a list of all the SDNTs. You can find it on your computer.”
Tenant: “You think if I could afford a computer I’d be living in a trailer and paying $200 per month rent?”
OFAC Agent: “If you don’t have a computer you can go to your library and look in the Federal Register. Although you’d have to look through them all.”
Tenant: “Okay, so let’s imagine I went and did that and found out that my landlord is a drug dealer in those Federal Register things. You mean I gotta stop paying him my rent? Are you nuts? These guys have guns.”
OFAC Agent: “That’s not really our problem, sir”
So what’s next? OFAC fines Miami couple $70 for paying bill in restaurant owned by SDNT? Nine-year-old fined $1.79 for buying pack of chewing gum in store owned by SDNT?
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