The Summer of 2006 OFAC Iranian Sanction Scandel

Mark Herpel
Can you remember what you were doing back in November 2006?

At that time, there was a small uproar across the Net because e-gold Ltd., had closed all Iranian accounts. Many Iranians were very angry, claiming that their accounts and funds had just disappeared. There were a few articles about the event, www.digitalmoneyworld.com... and quoting from this one, "It would appear, that ANY type of financial connection with Iran via the US at this time is a severe īno noī."

As it turns out, that was an understatement! At the time of the account closings, the e-gold service department had sent out this email:

Your account has been frozen in compliance with the laws which govern e-gold, Ltd. and its managers. e-gold, Ltd. has taken this step in strict compliance with the law. No further information is available at this time. When additional information is available it will be provided upon account login. Thank you.

Of course, if you were not living in downtown Tehran, you probably did not give this event much thought.

After November, everyone with a working e-gold account went on about their daily business. Inexchanges and outexchanges were happening at low rates and it was ībusiness as usualī. At that time, many e-gold users were working with a very popular exchange agent called Me-gold.com The company was widely used back then. I have recommended Me-gold and they are still a very good online e-currency business.

However, in those earlier years, users may not have realized that their Me-Gold exchange orders were being transacted through Iran. Me-gold was located in Iran.

At that time Iran was on the sanctioned country list. (still is today) It is against the rules for any US person to do business through a country on this list. If you want to find out more about these regulations, the Treasury Department puts out a sort of "Sanctions for Dummies" .pdf cleverly entitled "What You Need To Know About U.S. Economic Sanctions".

From the day that the Me-gold.com web site came online in August 2004 through February 2007 they were located and operated from Iran. The web site provides this information circa August 2004:
  • Business Name: Me-gold Kish Co.
  • Mr. Soleiman Founder & CEO
  • Legal status: Private joint-stock co.
  • Registration no.: 3641

  • A Strategic Island Called Kish, The Pearl of the Persian Gulf!
    Kish Island Located on the north east of the Persian Gulf with a minimum distance of 17 km from the southern offshore of the mainland Iran, the Kish island with an area of 90 square kilometres is one of the most marvelous and most beautiful regions of the Persian Gulf and has attracted the attention of many tribes and nations since times immemorial. Oval in shape, the island is 15 km long and 8 km wide. Already a famous island, Kish owes it present flourishing to its status as Iranīs first and, for a long time, the only free port, and its sweet water.
    The Iranian address was still present on the web site years later in February 2007. Address:
    P.O.Box 1167, Venus Center,
    Kish Island, Iran
    Are you one of the US persons who was exchanging digital currency with Me-gold during these years?


    Oh-oh....if you were doing financial business over the Net with Iran that was in direct violation of OFAC regulations!

    Donīt believe me? They call it "Trading with the Enemy". Here are two cases reported by the Office of Foreign Assets Control:

    ENFORCEMENT INFORMATION FOR

    July 11, 2008

    Information concerning the civil penalty process is discussed in OFAC regulations governing the various sanctions programs or, in the case of sanctions regulations issued pursuant to the Trading with the Enemy Act, in 31 CFR part 501. Civil penalty procedures are also discussed in OFACīs proposed Enforcement Guidelines, 68 FR 4422 – 4429 (January 29, 2003).

    ENTITIES – 31 CFR 501.805(d)(1)(i)

    One individual has agreed to a settlement totaling $840 for alleged violation of the prohibitions in the Iranian Transactions Regulations: OFAC alleged that in August 2006, the individual attempted to transfer funds to Me-Gold Kish, Co. in Iran in an apparent attempt to purchase electronic gold without an OFAC license. The individual did not voluntarily disclose this matter to OFAC.


    One individual has agreed to a settlement totaling $400 for alleged violation of the prohibitions in the Iranian transactions Regulations: OFAC alleged that in June 2006, the individual attempted to purchase electronic gold from Me-Gold Kish Co. in Iran in apparent violation of §§ 560.201, 560.203 and 560.204 of the Iranian Transactions Regulations. The individual did not voluntarily disclose this matter to OFAC.

    For more information regarding OFAC regulations, please go to:

    http://www.treas.gov/offices/enforcement/ofac/legal/

    A decade or two ago, this kind of thing could have never happened. However, today the Internet has made us all close cyber neighbors. We are next door neighbors with Iran.

    Who knew that International OFAC country sanctions could effect your daily e-currency exchange?

    Now - you - know.

    Me-gold is a fine operation backed by good people no matter what country they are in!

    At this time, to the best of our knowledge, we believe Me-gold.com is operated out of Dubai, UAE. The web site also reflects that information.

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    Mark Herpel

    A firm believer in sound money policy.
    Now publishing:
    Digital Gold Currency Magazine
    Community Currency Magazine