Last week, Buzzfeed published an expose describing how Reed Business Information (“RBI”), which publishes the widely used Banker’s Almanac, provided services to an array of unsavory financial institutions in sanctioned jurisdictions. Provocatively titled “As Assad Butchered His People, This London Firm Helped His Banks Trade,” the piece is based on interviews with two anonymous whistleblowers, as well as corporate documents retained by one of them, a former salesperson. According to the author, the documents “reveal in extraordinary detail how RBI’s London branch dealt with blacklisted institutions in Syria, Iran, North Korea, and Iraq.” While the report alleges significant moral and compliance failings, after reviewing the available information, the picture is far less clear.

The Banker’s Almanac (“BA”) is a massive online banking resource, providing counterparty information, payments codes, and other KYC data. Access to BA is important, though not essential, for international financial institutions to process international payments in a timely and cost-effective manner.

According to the whistleblower, images of Syrian civilians being gassed by the Assad regime prompted him to investigate whether RBI was aiding the regime by providing services to Syrian banks. Over the course of his investigation, he concluded that RBI systematically provided BA and other services to financial institutions subject to U.S., U.K., E.U., or United Nations sanctions, or some combination thereof. He produced a list of 28 “sanctioned” financial institutions that RBI may have been providing services to. The author of the piece infers that the “frenzied sales culture” of RBI led employees to either overlook or deliberately violate sanctions.

While these are certainly incendiary charges, they don’t entirely stand up to close scrutiny. Of the 28 sanctioned financial institutions, RBI extended a new BA subscription to two, Bank Melli and Bank Sepah, after they had been sanctioned by the E.U. Many of the compliance failures appear to be a failure to close existing accounts after sanctions had been imposed. While certainly a significant breach, RBI would by no means be the only company to have deficient internal procedures that led to failures. In fact, in the response letter to the whistleblowers complaint, counsel seems admit inadequate training and processes and hint that violations were disclosed to regulators.

Another category of alleged improper dealings were for RBI’s failures to comply with unilateral U.S. sanctions, beyond their legal duties. In some cases, such as with the Iran Venezuelan Bi-National Bank, the whistleblower seems to indicate that RBI should have cut off business ties before the entity was even subject to U.S. sanctions.

Moreover with many of the institutions, especially with Iran, U.S. sanctions policy is not to completely shut of all business activities with the banks. Continued activity is expected, or else the repeated exceptions for non-13224/13382 institutions would not have been included in sanctions legislation and executive orders. Additionally, General Licenses exist for a reason, so that some financial transactions continue to take place. Some of the author’s bias certainly is made clear by the repeated references to deals with “a bank in Iraq,” without mentioned that bank was the Central Bank of Iraq. One would be hard pressed to argue that Iraq’s Central Bank shouldn’t be able to access Banker’s Almanac.

None of which is to say that no violations occurred or that RBI was not slow to remediate deficient compliance practices. But as the RBI spokesperson quoted in the story makes clear, sanctions laws are in fact complex, not just in legal terms, but in the policy objectives that sanctions seek to achieve. Such a black-and-white treatment is inappropriate given the significant amount of gray that characterizes the field.