Feb

14

SDN List Hit Holds Up Food Bank Funds in Britain


Posted by at 11:12 pm on February 14, 2017
Category: Economic SanctionsOFACSDN List

Eventbrite Instagram Post via https://www.instagram.com/p/032C0eyzj7/?taken-by=eventbrite [Fair Use]So, UK accountant Mamunal Islam was minding his own business trying to raise money for a Bedford food bank. He thought maybe he’d sell tickets to a film through Eventbrite and use the proceeds to help people in his home town who needed food. He had never even heard of this obscure agency in the United States call the Office of Foreign Assets Control until San Francisco based Eventbrite told him that they were keeping his money and the hungry people in Bedford, well, they could eat cake. (Eventbrite didn’t really say the last part.)

It seems that Eventbrite thought that Mamunal Islam was a match on the SDN List, and although it never said that the food bank customers could eat cake, it did, according to an article on BBC News, say this:

Eventbrite said it was “truly sorry” but “a person with a very common name is more likely to make the list.” … Eventbrite said the Office of Foreign Assets Control (OFAC) had only recently added “M Islam” to its list. … A spokesman for the company said: “As a US company, Eventbrite must comply with US law. “In this instance, a payment to the organiser was temporarily held because of a potential OFAC name match. “Whether that is J Smith or M Islam does not make the slightest difference.”

To begin with, I don’t know what SDN List Eventbrite was using but it’s certainly not the one that OFAC publishes. Here’s every individual on the SDN List with Islam in his/her name:

ATABIEV, Islam SDN
ATABIYEV, Islam SDGT
ATABIYEV, Islam Seit-Umarovich SDGT
ABU ISLAM, Karim SDGT
ABU ISLAM SDGT
AL-SURIR, Abu Islam SDGT
AL-GADDAFI, Saif al-Islam LIBYA2
AL-QADHAFI, Saif al-Islam LIBYA2
EL-QADDAFI, Seif al-Islam LIBYA2
ELKADDAFI, Saif al-Islam LIBYA2
GADDAFI, Saif al-Islam LIBYA2
GADHAFI, Saif al-Islam LIBYA2
GHADAFFI, Saif al-Islam LIBYA2
GHATHAFI, Saif al-Islam LIBYA2
QADDAFI, Saif al-Islam LIBYA2
QADHAFI, Saif al-Islam LIBYA2
DEL ROSARIO SANTOS, Ahmad Islam SDGT

I don’t see any “M Islam” there, do you?  I don’t see anything even close other than “Islam” — which should not be cause to say that “Mamunal Islam” is a hit.  If sharing one part of a name is enough, than Eventbrite would need to block every Sally, Carol, José, Mohammed, Ahmed, Tom, Robert, Paul and James, because all those names also show up on the list.

Beyond this, Eventbrite had already burned the barn after the horses had escaped, so to speak.   If Mamunal Islam was really on the list — and he is not — then it would have been illegal to have sold any tickets on his behalf.  By the time there were actual funds to block, the rules had already been broken. So it’s not clear why Eventbrite didn’t tell Mr. Islam that there was an issue when he signed up or registered a new event rather than after he’d already sold a bunch of tickets for the food bank event.

Ultimately Eventbrite reversed its action after Mr. Islam provided “information confirming his country of birth” thereby proving, I suppose, that he is not the second son of Muammar Gaddafi.  So there was, ultimately, a happy ending, more or less, for Mr. Islam, Eventbrite, and the food bank in Bedford.

I understand that OFAC is in the business of scaring people to death and that Eventbrite’s reaction was not entirely irrational.  I’m also guessing that Eventbrite was the victim of one of the numerous paranoid screening services that market their value by claiming to screen against a semi-dubious list of sixty-two billion names of dodgy people.   Last, and perhaps least,  I’m sure “Islam” is scarier to an Internet company in San Francisco than, say, “Sally” or “Carol.”  Still, it seems that common sense should have prevailed here sooner than it did.

 

 

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