Danske Bank Estonia processed $160 billion through U.S. banks on behalf of these customers. According to DOJ, Vekselberg engaged in a conspiracy to commit bank fraud and money laundering by obfuscating his ownership interest in the Tango and therefore causing false information to be sent to U.S. banks processing transactions for the Tango. [cxlv] The SEC further alleges that although Danske Bank knew of the high-risk transactions associated with its Estonian branch, it made materially misleading statements and omissions in its public reports regarding its compliance with AML obligations, specifically that Danske was compliant with its legal obligations to prevent its services from being used for illicit purposesincluding money launderingand that it had effectively managed these risks. If you need immediate assistance, please contact support@trellis.law. [xv] U.S. Dept of Treasury, Venezuela General License 40A (Jul. [xxiii] Following the initial designation, several former users of Tornado Cash, who have cryptocurrency locked in Tornado Cash, filed a complaint against OFAC in the U.S. District Court for the Western District of Texas, alleging that OFACs designation of Tornado Cash violated the Administrative Procedure Act because it exceeds OFACs statutorily delegated authority, violates the plaintiffs First Amendment rights, and violates certain plaintiffs due process rights.[xxiv]. Any cookies that may not be particularly necessary for the website to function and is used specifically to collect user personal data via analytics, ads, other embedded contents are termed as non-necessary cookies. ", 2023 Paul, Weiss, Rifkind, Wharton & Garrison LLP. Nyc Toll Holdings Limited. Oct. 19, 2022). On September 26, 2022, OFAC announced that CFM Indosuez Wealth (CFM), an indirect subsidiary of Credit Agricole Corporate and Investment Bank (CACIB), agreed to a settlement of $401,038 to resolve apparent violations of U.S. sanctions that occurred when CFM had operated USD banking and securities accounts on behalf of 11 individual customers located in comprehensively sanctioned jurisdictions and had processed payments on behalf of these customers through the U.S. financial system. With more than one million buildings in the Big Apple, it is imperative for these structures to adhere to safety regulations and laws that are set forth by the citys Department of Buildings (DOB). DOB NOW is unavailable due to maintenance. [clviii] In addition to the monetary penalty, Robinhood Crypto is required to maintain an independent consultant for an 18-month term that reports to DFS and to conduct a comprehensive review of its compliance programs. represented by [civ] Though Ofer was trained in AML compliance and procedures and had worked in international banking for decades, he failed to implement an AML program. The information provided is not legal advice. Russian Elites High-Value Assets Alert. CA Indosuez (Switzerland) S.A. On September 26, 2022, OFAC announced a $750,258 civil settlement with CA Indosuez (Switzerland) S.A. (CAIS), an indirect subsidiary of Credit Agricole Corporate and Investment Bank (CACIB), relating to banking and securities accounts that CAIS operated on behalf of 17 individuals for approximately three years in violation of OFACs Cuba, Ukraine-related, Iran, Sudan, and Syria sanctions programs. [xliv] Most of the violative transactions occurred within hours after OFAC had designated the two individuals. As relevant here, the EO noted the role of digital assets in sophisticated cybercrimerelated financial networks and activity, including through ransomware activity.[clxxvi] The EO called for a cross-governmental team of law enforcement agencies to submit multiple reports to address this riskincluding one that is to be submitted to Congress on the trends in the use of digital assets by illicit actors. Apr. 2339B. Hi Sara! [xxxiv] Paul, Weiss, OFAC Enforcement Action Again Highlights the Importance of IP Address Blocking; OFAC Also Issues Guidance for Instant Payments Industry, (Oct. 6, 2022), available here. International trade counsel Richard Elliott was featured in the Global Investigations Reviews most recent issue, which lists him among the 25 most respected sanctions lawyers in Washington, D.C. Firm chairman Brad Karp, corporate partner Mark Bergman and litigation partners Susanna Buergel, Roberto Gonzalez, Jane OBrien and Elizabeth Sacksteder have been selected to receive theLaw360Distinguished Writing Award at the 2019, Firm chair Brad Karp was named the 2018 New York Law Journal Attorney of the Year.. Talk to a Licensed Professional Engineer today. The U.S. District Court for the District of Columbia issued the seizure warrant, calling the seizure of the yacht just the beginning of the reckoning that awaits those who would facilitate Putins atrocities. (MoneyGram). OFAC further determined that another SDN, Ruslan Gadzhiyev, is a beneficiary of the trust, which OFAC stated was a separate and independent basis for Heritage Trust to receive the notification of blocked property. The task force is being run by Deputy Attorney General Lisa Monacos office and led by Andrew Adams, a veteran prosecutor from the Southern District of New Yorks U.S. Attorneys Office (SDNY). Following are the notable changes: Violations are electronically One day after announcing Task Force KleptoCapture, on March 3, 2022, DOJ unsealed a criminal indictment charging Jack Hanick, a U.S. citizen, with providing services to a Russian oligarch who had been sanctioned in 2014 for financing Russias malicious activities in Ukraine. On December 13, 2022, the SEC announced a $413 million settlement with Danske Bank, a Danish financial services corporation with ADRs trading in the U.S., for misrepresenting the strength of the AML compliance program of its Estonian arm to investors, and for failing to divulge the risks associated with the programs deficiencies. 9, 2022), available here. Where not restricted by law, there other concerns with using a portable machine: Thereafter, Reporting Companies will have 30 days to report any changes to FinCEN. On September 29, 2022, DOJ unsealed an indictment charging sanctioned Russian oligarch Oleg Deripaska, his two associates, and a U.S. citizen with a scheme to evade U.S. sanctions and obstruct DOJs investigation into the same. Hsbc Bank Usa, N.A., As Trustee On Behalf Of Ace Securities Corp. Home Equity Loan Trust And For The Registered Holders Of Ace Securities Corp. Home Equity Loan Trust, Series 2006-He4, Asset Backed Pass-Through Certificates, et al. [xxxii] According to OFAC, BPPR processed 337 transactions totaling $853,126 on behalf of two individuals who were low level employees of the Government of Venezuela (GoV), in apparent violation of U.S. sanctions against Venezuela. The violation is entered against the property in the Department's Buildings Information System (BIS), and must be corrected before a new or amended Certificate of Occupancy (CO) can be obtained. In April 2022, OFAC issued detailed guidance regarding the additional general licenses and FAQs with respect to Afghanistan that OFAC had issued in a series of actions in late 2021 and early 2022. [clix] DFS found, among other things, that Robinhood Crypto (i) failed to maintain a compliant AML program as required by New Yorks Virtual Currency Regulation and as part of Robinhood Cryptos registration with DFS as a money transmitter; (ii) violated DFSs Part 504 regulation by failing to maintain an appropriate transaction monitoring system and submitting an improper certification of compliance; and (iii) violated DFSs Part 500 regulation by failing to maintain a compliant cybersecurity program and submitting an improper certification of compliance. Beneficial Ownership Information Reporting Rule. This web site contains attorney advertising. OFAC ultimately determined that, with respect to both Newmont and Chisu, the apparent violations were non-egregious. [lxxii] FinCEN found undetected suspicious transactionsincluding direct transactions with online darknet marketplacesduring the relevant time period, despite the fact that Bittrex did not file a single SAR from its founding in 2014 through May 2017, and only one from May 2017 until November 2017. OFAC determined that, although Tango Card maintained IP blocking and sanctions screening procedures for its direct customers (i.e., merchants), Tango Card did not maintain such procedures with regard to the recipients of rewards (i.e., the merchants customers and employees) despite collecting information, including such recipients IP addresses and email addresses, during the normal course of its business. As discussed in our prior memorandum,[xciii] on April 4, 2022, DOJ announced that Spanish law enforcement, acting pursuant to a request from the DOJ, executed a Spanish court order freezing sanctioned Russian oligarch Viktor Vekselbergs luxury yacht, the Tango, in the port of Palma de Mallorca. How are you using this technology? The violations stemmed from MidFirsts sanctions screening vendor notifying MidFirst that the individuals had been added to the SDN List 14 days later than they actually had. 1:21-cr-000174 (E.D.N.Y. Violations - Buildings - New York City [clxxiii] The White House, Executive Order on Ensuring Responsible Development of Digital Assets (Mar. The Department of Justice (DOJ) has filed several indictmentsincluding against U.S. and Russian personsfor violating Russian sanctions and related financial crimes, and has obtained several seizure orders for sanctioned [lxxv] U.S. Dept of Treasury, Financial Crimes Enforcement Network, FinCEN Assesses $275,000 Civil Money Penalty against A&S World Trading for Violating Geographic Targeting Order (Apr. We are checking for the latest updates in this case. This case represents the first time in which DOJ has brought such a material support charge against a corporation. Your content views addon has successfully been added. After attempted payment of the invoice was rejected by a U.S. financial institution due to sanctions-related concerns multiple times between August 2015 and 2016, S&P Global employees re-issued and re-dated the August 2015 invoice several times between August 2016 and October 2017 as Rosneft made partial payments. Additionally, Deripaskas associates assisted his girlfriend in traveling from Russia to the United States to give birth to their child. A copy of the notice is entered into the DOBs, As we mentioned before, these violations dont always come with monetary fines attached. The U.S. government also imposed prohibitions on the importation into the United States of Russian-origin energy products (e.g., crude oil, petroleum, liquified natural gas, coal) and Russian-origin fish, seafood, alcohol, and diamonds. WebThe table below defines the parking violation codes in New York City and lists the fines. It's the "secret" behind why things like affirmations, imagery, and mirroring can be so transformational. Mobile Electronic Violations - Buildings - New York City DOB violations are shown without an asterisk next to the violation number; dismissed DOB violations are shown with an asterisk, e.g., V*7052-18P. Commn v. J.H. [lxxii] FinCEN, In the Matter of Bittrex, Inc., No. Open violations can prevent an owner from selling or refinancing. You have exceeded your document request limit for this month. [vid_likes] 1473351556 data collection sheet, Free MATLAB Trial: Request a Quote: Contact Us: Learn more about MATLAB: [vid_likes] 1498760598 data analysis tools, [vid_likes] 1491399396 Market Research, [ad_1] PORTLAND, Ore., April 8, 2021 /PRNewswire/ Allied Market Research published a report, titled,E-health Marketby Type (Electronic Health Record (HER); Vendor Neutral Archive (VNA), Picture Archiving, & Communications Systems (PACS); Laboratory Information Systems (LIS);. [cliv] The guidance noted that virtual currencies, by their nature, typically enable provenance tracing thereby allowing a historical view of a virtual currency transmission between wallet addresses, providing the opportunity for greater visibility into transaction lineage that is typically found with traditional, fiat funds transfers.[clv] The guidance further cited the storage of identifying information such as sending and receiving wallet addresses, time and date, and value of transaction by virtual currencies, as a useful tool in AML efforts.[clvi]. WebAffordable Housing for Rent 700 Manida Street 96 NEWLY CONSTRUCTED UNITS AT 700 Manida Street, Bronx, NY 10474 -Income Affordability Program of the New York City Department of Housing Preservation & Development (HPD) Who Should applications are selected for review through a lottery process. Use the Step by Step tool to get an exhaustive list of requirements that matter to you. Litigation partner Roberto Gonzalez has been named to the Hispanic National Bar Association's (HNBA) 2016 list of the twenty "Top Lawyers Under 40. [cxiv] The indictments and associated plea deals come after FinCEN and the CFTC levied a $100 million civil money penalty in consent orders with BitMEX for violations of the BSA and the Currency Exchange Act in August 2021.[cxv]. A few days later, Amexs internal sanctions list screening system generated a high confidence alert that was erroneously closed by an operations analyst responsible for conducting the initial review of the alert despite a match against multiple data elements and an internal procedural requirement for a second-level review for all high-confidence alerts. 1, 2022), available here. As described in our prior memorandum,[clvii] on August 9, 2022, the DFS announced a $30 million consent order against Robinhood Crypto, LLC (Robinhood Crypto), a wholly owned subsidiary of Robinhood Markets Incorporated, which offers cryptocurrency trading. [xvii] OFAC explained that it issued GL41 consistent with longstanding U.S. policy to provide targeted sanctions relief based on concrete steps that alleviate the suffering of the Venezuelan people and support the restoration of democracy.[xviii] GL 41s issuance also coincided with significant changes in the domestic politics of Venezuela at the end of 2022 and beginning of 2023, including, most notably, the Venezuelan oppositions removal of Juan Guiado as Interim President, a position he had held since 2019, and shifting coalitions in the Venezuelan National Assembly. The Tornado Cash designation is further reaching and novel as, unlike Blender, Tornado Cash is not operated under centralized control. Frozen Sandwiches Market The Latest survey report on Global Frozen Sandwiches Market sheds lights on changing dynamics in Food & Beverages Sector and elaborates market size and growth pattern of each of Frozen Sandwiches segments. It's been a while since I have put this out there, but even with the current state of the debt markets, Rockledge is still fully looking at all extended stay hotel deals across the country. [xliv] U.S. Dept of Treasury, OFAC Issues a Finding of Violation to MidFirst Bank for Violations of the Weapons of Mass Destruction Proliferators Sanctions Regulations (July 21, 2022), available here. [xxx] Danfoss A/S is a Danish manufacturer and seller of refrigeration products, air conditioners, compressors, and other cooling products. Start: Mar 2, 2023 $15 Off. Find Building Data - Buildings - New York City [clxxv] Executive Order, supra note 173. [xlvi] Paul, Weiss, OFAC Enforcement Action Shows Risk of Extending the Length of Credit Extended to Russian Companies Targeted by Debt Sanctions, (Apr. DOB NOW - Government of New York City This translates to much longer exposures and inability to penetrate larger patients for anything other than extremities; Those customers utilized third-party agents such as money exchangers in non-sanctioned jurisdictions to make the transfers. In December 2022, the U.S. government along with the European Union and the G7 member nations announced a novel joint $60-per-barrel price cap on seaborne crude oil of Russian origin, to be enforced by means of a prohibition on the provision of certain services (including maritime insurance and trade finance) related to the maritime transport of Russia-origin crude oil where the price cap is exceeded.[v]. [xxxv] The settlement resolved 27,720 transactions with persons with an internet protocol (IP) address or email address associated with Cuba, Iran, Syria, North Korea, and the Crimea region that resulted in apparent violations of U.S. sanctions. This button displays the currently selected search type. Pls pay it forward by liking and commenting to spread. Link in comments. DOB If a building is not in compliance with the DOBs laws, it will get issued a violation. Building on My Block /. [clxix] Coinbase will pay a $50 million penalty for violating the New York Banking Law and DFS virtual currency, money transmitter, transaction monitoring, and cybersecurity regulations. [lxvii] U.S. Dept of Treasury, FinCEN Alert on Human Smuggling along the Southwest Border of the United States, FIN-2023-Alert001 (Jan. 13, 2023), available here. Rather, the guidance notes OFACs expectation that financial institutions will make decisions on whether and how to screen transactions using instant payment systems based on each institutions assessment of its own risk. Search the Public Portal - Government of New York City The violation is entered against the property in the Department's Buildings Information System (BIS), and must be corrected before a new or On the tech side we are taking steps towards using an #api so that clients can ask questions about our 50k listings, 3,000 lenders, and 1mm sales comps. [clxx] In addition to the penalty, Coinbase agreed to invest an additional $50 million in its compliance function over the next two years to remediate the issues and to enhance its compliance program pursuant to a plan approved by DFS. On May 27, 2022, OFAC announced a $255,937.86 settlement with Banco Popular de Puerto Rico (BPPR), a Puerto Rican bank with branches in Puerto Rico and the Virgin Islands, related to violations of the Venezuela Sanctions Regulations. [clxxii] Paul, Weiss, Biden Issues Executive Order Instituting a Whole-of-Government Approach to Supporting Digital Asset Innovation and Mitigating Its Risks (Mar. On May 20, 2022, the SEC announced a $7 million settlement with Wells Fargo Advisors for failing to timely file at least 34 SARs. [lxxxvii] The task force is staffed by prosecutors, agents, and analysts across DOJ with expertise in sanctions, export control, anticorruption, asset forfeiture, AML, tax enforcement, and national security investigations, as well as personnel from other departments and agencies, including the Department of Homeland Security and the IRS. [cxxxiv] Off. Co-founder @ Silbo. [cxiii] Under the terms of his plea agreement, Dwyer also agreed to separately pay a $150,000 criminal fine representing pecuniary gain derived from the offense. of Comp. Harmon, who was later indicted by the DOJ, pleaded guilty to a money laundering conspiracy on August 18, 2021. For full print and download access, please subscribe at https://www.trellis.law/. 10482 (S.D.N.Y. This is the greatest explanation and insights in to how the next and future steps will play out between Microsoft vs Google with the power of #ai and #chatgpt This website uses cookies to improve your experience. Consultant 28+ years experience. [xi] The White House, Executive Order on Taking Additional Steps to Address the National Emergency with Respect to the Situation in Nicaragua (Oct. 24, 2022), available here. On four occasions between 2016 and 2017, the companies imported Cuban-origin explosives and explosive materials in violation of the Cuban Assets Control Regulations. Moreover, the company failed to correct these failures even after the Internal Revenue Service (IRS) identified the 114 missing GTO reports during an examination in September 2015. [iv] Shortly thereafter, OFAC also prohibited the export by U.S. persons of certain categories of services to Russia, including accounting services, trust and corporate formation services, and management consulting services. [clxxxv], On October 21, 2022, the first Plenary of the Financial Action Task Force (FATF) issued guidance identifying jurisdictions under increased monitoring and those subject to a call for action.[clxxxvi] Jurisdictions under increased monitoring are those that are actively working with the FATF to address the strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing.[clxxxvii] New jurisdictions subject to increased monitoring included the Democratic Republic of Congo, Mozambique and Tanzania. A question frequently ariseswhy can't #urgentcare utilize portable x-ray like the hospital #emergencydepartment ? 2022), Dkt. [xxvii] Paul, Weiss, OFAC Enforcement Action Again Highlights the Importance of IP Address Blocking; OFAC Also Issues Guidance for Instant Payments Industry (Oct. 6, 2022), available here. On March 17, 2022, FinCEN announced a $140 million consent order against USAA. This memorandum surveys U.S. economic sanctions and anti-money laundering developments and trends in 2022 and provides an outlook for 2023. OFACs 16 public enforcement actions highlight OFACs broad assertion of jurisdiction and its increasing focus on non-U.S. companies. On April 14, 2022, FinCEN issued an advisory to financial institutions to help them identify the typologies and red flags associated with corruption by foreign public officials, including those who use their position and influence for personal gain (or, kleptocrats). Companies need to perform market research because it will help them; identify marketing opportunities, monitor, Python data analysis / data science tutorial. Guidance for Instant Payments Industry. Chief Executive Officer at Empower ABA Therapy. 1, 2022), available here. In waves of designations in the months following the invasion, OFAC added hundreds of Russian individuals and entities to the SDN List. Co-founder, COO @ LINK Home Therapy | Transforming Healthcare One Interaction at a Time | Doctor of Physical Therapy. [lvii] To ensure the existence of adequate safeguards, a financial institution that wishes to share SAR information would need to submit a written application to FinCEN. OFAC found that, while it found no evidence that Danfoss willfully used third-party payers for the purpose of evading sanctions, Danfoss FZCO was aware since at least 2011 that using a U.S. financial institution to send or receive payments related to sanctioned jurisdictions could be prohibited. Litigation partners Roberto Gonzalez and Jessica Carey wrote an expert analysis chapter in Global Legal Insights Blockchain & Cryptocurrency Laws and Regulations 2023. Proposed Rulemaking Regarding Access to Beneficial Ownership Information. try clicking the minimize button instead. Advisory on Kleptocracy and Foreign Public Corruption. [cviii], BitMEX Founders and Executives Guilty Pleas. [cxii] U.S. Dept of Justice, Third Founder Of Cryptocurrency Exchange Pleads Guilty To Bank Secrecy Act Violations (Mar. President Bidens Proposal to Facilitate Russia-Related Asset Seizures. [xx] U.S. Dept of Treasury, U.S. Treasury Issued First-Ever Sanctions on a Virtual Currency Mixer, Targets DPRK Cyber Threats, available here. Advisory on Elder Financial Exploitation. [cxxvii] As a result, the guidance emphasized that supervised banking organizations should notify their lead supervisory point of contact at the FRB (1) prior to engaging in any activity involving cryptocurrency, and (2) about any existing activity if they had not already done so. A new rule from the OCC, effective May 1, 2022, allows the agency to issue exemptions from the requirements pertaining to the filing of SARs (including recordkeeping, confidentiality, and other requirements) upon the request of a covered institution. There are 21 examples on how one can remove barriers and weve provided the top 5 solutions. [xxviii] U.S. Dept of the Treasury, Sanctions Compliance Guidance for Instant Payment Systems (Sept. 30, 2022), available here. Reserve Sys., Fed. 2, 2022), availablehere. Accordingly, DOB is reminding all builders, contractors, crane operators, and property owners to secure their construction sites, buildings, and equipment. NLP. 5 Common New York City Building Code Violations and How to 10-1 (statement of facts). The City has tried to provide you with correct information on this website. DOB NOW - Safety Violations - Government of New York City [ix] In conjunction with these designations, OFAC issued a general license permitting transactions ordinarily incident and necessary to wind down dealings with ENIMINAS and its subsidiaries for one month (this general license expired in July 2022). Prior results do not guarantee a similar outcome. Lets go! [xciv] DOJ Press Release, $90 Million Yacht of Sanctioned Russian Oligarch Viktor Vekselberg Seized by Spain at Request of United States (Apr. [lxxxviii] Tightening the Screws on Russia: Smart Sanctions, Economic Statecraft and Next Steps Statement of Andrew Adams, Hearing Before the S. Comm. The drivers and restrictions are usually put together, HydroSurv and Sonardyne have completed a demonstration project involving HydroSurvs Uncrewed Surface Vessel (USV) and Sonardynes acoustic communications technology, whose combined capabilities the two companies showcased at the site of the Valorous floating wind project,, New Jersey, United States This Data Center Construction Market research examines the state and future prospects of the Data Center Construction market from the perspectives of competitors, regions, products, and end Applications/industries. Proposed Rule for Sharing of Suspicious Activity Reports. (Subcribe to view) As discussed in our prior memorandum,[cix] in August 2021, the SDNY indicted crypto derivatives exchange BitMEX founders Arthur Hayes, Benjamin Delo, and Samuel Reed, and BitMEX former executive Gregory Dwyer on charges of violating the BSA and conspiracy to violate the BSA. [clvii] Paul, Weiss, NY DFS Announces First Crypto Enforcement Action Against Robinhood Crypto for AML and Cybersecurity Compliance Deficiencies (Aug. 9, 2022), available here. [li] Specifically, the proposed rule provides that FinCEN may only disclose BOI to (i) federal agencies engaged in national security, intelligence, or law enforcement activities; (ii) state, local, and Tribal law enforcement agencies that obtain court authorization; (iii) U.S. Department of the Treasury officers and employees who require access in order to perform their official duties; (iv) certain authorized foreign law enforcement agencies and judicial and government authorities; and (v) financial institutions that need the information in order to comply with FinCENs 2016 CDD rule, provided that the relevant reporting company has consented to the disclosure. OFAC penalties for 2022 reached nearly $43 million, which is more than double the total penalties that OFAC imposed in each of 2021 or 2020. On April 6, 2022, DOJ unsealed an indictment charging Konstantin Malofeyev, a Russian oligarch and SDN, with conspiracy to violate U.S. sanctions and violations of U.S. sanctions in connection with his hiring of Jack Hanick, as described above. Fact Sheet: Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People. According to OFAC, this gap in Krakens sanctions compliance procedures resulted in some customers who had established accounts while outside Iran engaging in transactional activity through those accounts while they were apparently located in Iran, despite the IP address data of such customers at the time of the transactions being available to Kraken. The NYC Department of Buildings will only recognize the NYC DOB Training Connect SST ID card as valid proof of worker site safety training. NYC Department of Small Business Services. 8, 2022), available here. [liii] That law also expands the type of actions for which whistleblowing incentives are available, including certain sanctions-related actions. To apply for a job with Built Engineers, please send a cover letter together with your resume. New York City Department of Buildings Although OFAC had issued General License 34A (GL 34A), OFAC found BPPRs failure to identify the two employees for 14 months after the Executive Order was issued (where the bank possessed documentation at the time of the Executive Order showing that the individuals were employees of GoV) to be an aggravating factor in calculating the monetary penalty; however, OFAC found the case to be non-egregious, citing as mitigating factors enhancements to BPPRs program to better ensure compliance with OFAC sanctions. The cumulative effect of these sanctions has been to make Russia (and to a lesser extent Belarus) a quasi-comprehensively sanctioned country from a U.S. perspective.
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