“Well, it is not the transactions themselves that are of primary concern—although we do question what they may be for—but instead the bank’s propensity not to report them. Mr. Nasir’s companies also regularly transfer substantial sums of money to numerous offshore tax havens, and to a number of banks and companies that we believe are questionable themselves. Then they also regularly send money to countries that are on the OFAC list of questionable destinations.”
“OFAC list?”
“Office of Foreign Assets Control, Mr. Kariokos, they’re an agency of the U.S. Treasury Department that administers and enforces economic and trade sanctions in support of national security. OFAC maintains lists of all the governments, companies, individuals, and so forth, who are considered to be a threat to our nat
