Opinion No. 37 / 2006 of 27 September 2006, O. Ref.: SA2 / A / 2006 / 037- CONCERNING: Opinion on the transfer of personal data by the CSLR SWIFT by virtue of UST (OFAC) subpoenas.”During its session of 5th July 2006, the Commission had already made the decision to officially start an investigation into this case on grounds of article 32 § 1 DPL1, regarding the processing of personal data under the responsibility of SWIFT, a cooperative society under Belgian law, with headquarters in Belgium and with limited liability…As far as the communication of personal data to the UST is concerned, the Commission is of the opinion that SWIFT finds itself in a conflict situation between American and European law and that SWIFT at the least committed a number of errors of judgement when dealing with the American subpoenas. It must be considered a serious error of judgement on the part of SWIFT to subject a massive quantity of personal data to surveillance in a secret and systematic manner for years without effective grounds for justification and without independent control in accordance with Belgian and European law…”