Jan

15

OFAC List Prevents Professor From Slaying Imaginary Dragons


Posted by at 10:51 am on January 15, 2016
Category: OFACSDN List

Epic Building by Epic Games via https://epicgames.com/images/values/epic_building.jpg [Fair Use]
ABOVE: Epic Games HQ

Although I confess to being baffled as to why grown-ups play online video games (at least until after they have read the entire Western canon), recently a grown-up (and a college professor at that) pitched a fit after the OFAC blocking software of Epic Games choked on his name and told him he was not allowed to open an account with them and play one of their video games. More fun probably than playing the video game (and pretending to be a buff warrior in possession of awesome weapons and spells) is unraveling what occurred next.

Muhammad Zakir Khan, an assistant professor at Broward College in Florida, tried to sign up for an account online with Epic Games in order to play something called “Paragon” (which sounds more like a dish detergent than a video game, but that’s another issue). His effort to create the account was refused, and he was informed that this was because of a match against the SDN List, something that Mr. Khan had never heard of, so, like any other online warrior, he took the battle to Twitter, tweeting:

@EpicGames My name is Khan and I am not a terrorist.

Within a just a few hours, the CEO of Epic Games responded (via Twitter of course):

Sorry, this isn’t intended. We’re working to fix ASAP. Cause: Overly broad filter related to US trade restrictions.

Later, he tweeted how they thought they might fix the problem:

We’re working to figure this out. Ideally, not at signup, but by matching name and billing address at purchase time.

Obviously Epic deserves some credit for its efforts to take on OFAC and its SDN list, even though phaser energy guns and revivifying potions are of no use against either. Unfortunately, once there is a name match there is no simple automated solution to resolving the hit. In the case of Mr. Khan, having his address would have been useless because there is no address listed for the Mohammad Khan on the SDN List that caused the hit. Indeed, there is no single adequate way that one can automate resolving false hits. Computers may be able to drive cars, vacuum your living room, and play Jeopardy, but this is something that best practice requires be done by an actual human being.

But there is another point to be made here. Why on earth do we care at all whether terrorists and narcotics kingpins spend money to play online video games? In fact, wouldn’t we prefer that terrorists and drug dealers spend more time slaying imaginary dragons and enemies on their computers and less time doing what they do in the real world?

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Copyright © 2016 Clif Burns. All Rights Reserved.
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9 Comments:


Alas many online game accounts provide for purchase of advanced weapons and other “military” resources for use within the game.

Comment by Michael Scott on January 15th, 2016 @ 11:13 am

In Brown v. Entertainment Merchants Ass’n, the Supreme Court held that video games are free speech protected by the First Amendment. Query how far such an argument might be pressed in this context to render the SDN-related prohibition unconstitutional.

Comment by Rich Matheny on January 15th, 2016 @ 1:15 pm

Some video games allow chats between users that are anonymous and have been used by rogues to communicate their evil plans.

Comment by GWS on January 15th, 2016 @ 3:58 pm

So the next game the company will develop will be “The Wrath of Khan?”

Comment by Marian on January 16th, 2016 @ 5:18 am

The link points to Fazal Rahim. There are two hits for Mohammad Khan:
https://sanctionssearch.ofac.treas.gov/Details.aspx?id=3080
https://sanctionssearch.ofac.treas.gov/Details.aspx?id=3227

There is still no address, but there are dates of birth. Perhaps the software could require that, because you can’t lie about your age on the internet.

Comment by Steve on January 18th, 2016 @ 11:47 am

    That’s odd that the link no longer points to Khan. Perhaps those ID numbers change, because it did point to him originally.

    Comment by Clif Burns on January 18th, 2016 @ 11:58 am

I can buy a virtual axe in World of Warcraft and sell it for real world money. Is there a money-laundering opportunity there?

Asking for a friend.

Comment by Eric on January 19th, 2016 @ 9:39 am

Them being a US company meant this was absolutely inevitable. So no surprises here. I’m pretty sure the future players in the off chain microtransaction space aren’t going to be US companies. Now that I think about it, 21 is crazy for still being in the US considering they see microtransactions as the primary use case for their business.

Comment by Neil on January 19th, 2016 @ 12:14 pm

Ah, Broward College, the alma mater of Marilyn Manson.

On a more serious note, MMOs could theoretically (as noted by GWS) provide back channels of communication. The Director of National Intelligence noted it in a threat assessment in 2008, and there have been a couple studies of how virtual behavior and real-world behavior interact. It’s not the game that’s the threat, it’s the in-game communication. I’m not aware of any proof of such communications, but it’s not something I’ve read up on in the past few years.

All that said, such a block would be a momentary inconvenience. All the person would need to do is have someone who’s not an SDN create an account and give them the login details. Sure, it’s a violation of the Terms of Service, but somehow I doubt either a terrorist organization or a drug cartel will be that concerned about a TOS violation, given their other activities.

Comment by SK on January 19th, 2016 @ 4:01 pm