OFAC: 2013 Investigation of Royal Bank of Scotland Plc (MUL-651983)

David Scantling filed this request with the Department of Treasury, Office of Foreign Asset Control of the United States of America.
Tracking #


Est. Completion None


From: David Scantling

To Whom It May Concern:

This is a request under the Freedom of Information Act ("FOIA"). I hereby request the following records:

All Office of Foreign Asset Control ("OFAC") documents, reports, files, database records, and electronic-mail messages (hereafter “documents”) related to OFAC's 2013 investigation of Royal Bank of Scotland Plc (including its subsidiaries and branches)(designated as OFAC case number MUL-651983).

The following constraints limit this FOIA request:

1. The inclusive dates of November 1, 2013, to December 15, 2013;

2. Excluding any documents containing the agency’s deliberative material or recommendations;

3. Excluding any documents classified Top Secret (“TS”), Sensitive Compartmented Information (“SCI”), and/or Special Access Program (“SAP”); however,

4. Including all of the agency’s responsive documents classified below the TS, SCI and/or SAP levels; for example, any documents marked: Unclassified ("U"), Sensitive But Unclassified ("SBU"), For Official Use Only ("FOUO"), Confidential ("C"), Law Enforcement Sensitive ("LES"), and/or Secret ("S").

Although FOIA has always presumed that government records are open to public inspection, the FOIA Improvement Act of 2016, Pub. L. 114-185, prohibits agencies from withholding records unless (1) “disclosure is prohibited by law” or (2) “the agency reasonably foresees that disclosure would harm an interest protected by” one of FOIA’s exemptions. 5 U.S.C. § 552(a)(8)(A). Thus, in addition to FOIA favoring disclosure and requiring its exemptions to be narrowly construed, Section 552(a)(8)(A) prohibits agencies from using their discretion to broadly withhold records merely because they believe an exemption could technically apply.

In order to expedite the agency’s release of the requested documents, please disclose them on an interim, rolling basis as they become available; for example, without waiting for all of the agency’s relevant systems of record to be searched, or all of its relevant records to be processed. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

If the agency’s processing costs for this request exceed $350.00, please notify me in advance so that I might consider paying any additional fees for a complete and accurate set of the agency's responsive documents.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 20 business days, as the statute requires.


David Scantling


Good Morning Ms. Scantling,

Our office is in receipt of your email and three FOIA requests addressed as a follow up to the FOIA requests you indicated you had previously submitted. Please note that I conducted a search of our database and did not locate the FOIA requests included with your follow up correspondence. The three FOIA requests have been given the FOIA tracking numbers indicated in our acknowledgement letter. Please refer to the FOIA tracking numbers and other information provided in the acknowledgement letter when inquiring about your requests.

Thank you,



Mr. Scantling,

This concerns your FOIA requests, outlined in the table below, which have been assigned to the Office of Foreign Assets Control (OFAC) for processing.

We would appreciate the opportunity to discuss these requests with you. To that end, what are your periods of availability to speak with us on Thursday (March 30, 2017) and Friday (March 31, 2017), between the hours of 10 AM and 3:00 PM ET? Also, please provide us with the phone number we should use to contact you.


Request Description


Documents dated between July 1, 2013, and June 30, 2014 that relate to OFAC's investigation of BNP Paribas SA (involving OFAC case number COMPL-2013-193659).


Documents from November 1, 2012 through December 15, 2012 related to OFAC's 2012 investigation of HSBC Holdings Plc (including its subsidiaries and branches), designated as OFAC case number MUL-615225.


Documents from November 1, 2009 through December 31, 2009 related to OFAC's 2009 investigation of Lloyds TSB Bank Plc (including its subsidiaries and branches), designated as OFAC case number MUL-4745344.


Documents from November 1, 2013 through December 15, 2013 related to OFAC's 2013 investigation of Royal Bank of Scotland Plc (including its subsidiaries and branches), designated as OFAC case number MUL-651983.


Documents from October 1, 2009 through December 16, 2009 related to OFAC's 2009 investigation of Credit Suisse AG (including its subsidiaries and branches), designated as OFAC case number MUL-473923.

If you have any questions regarding this matter, you may email us at OFACFOIAOffice@treasury.gov<mailto:OFACFOIAOffice@treasury.gov> or contact the FOIA Requester Service Center at (202) 622-2500, option 3.




  • 03/03/2017

    Receipt Letter 2017-03-028 - 2017-03-030_FINAL