Full opinion text
Beryl A. Howell, Chief Judge In December 2017, the United States Attorney for the District of Columbia served two Chinese banks-Bank One and Bank Two-with a grand jury subpoena, and a third Chinese bank-Bank Three-with an administrative subpoena. All three subpoenas are for records of transactions for [REDACTED], a now-defunct Hong Kong based front company for North Korea's state-run [REDACTED]. Each bank refused to comply. Almost a year later, on November 29, 2018, the government moved to compel each bank's compliance with their respective subpoena. See Gov't's Mot. Compel. Produc. Docs. Req. Via Bank of Nova Scotia Subpoenas-Bank One ("Gov't's Mot.-Bank One"), ECF No. 1 (No. 18-175); See Gov't's Mot. Compel. Produc. Docs. Req. Via Bank of Nova Scotia Subpoenas-Bank Two ("Gov't's Mot.-Bank Two"), ECF No. 1 (No. 18-176); Mot. Compel. Produc. Doc. Req. Via Administrative Subpoena ("Gov't's Mot.-Bank Three"), ECF No. 1 (No. 18-177). Consistent with the parties' agreed upon briefing schedule, on January 7, 2019, each bank filed an opposition, supported by voluminous attachments, to the government's motion. See Bank One's Opp'n to Gov't's Mot. Compel ("Bank One's Opp'n"), ECF No. 6 (No. 18-175); Bank Two's Opp'n to Gov't's Mot. Compel ("Bank Two's Opp'n"), ECF No. 3 (No. 18-176); Bank Three's Opp'n to Gov't's Mot. Compel ("Bank Three's Opp'n"), ECF No. 4 (No. 18-177). The government then filed a single omnibus reply, on February 4, 2019, with its own attachments. See Gov't's Omnibus Reply Supp. Mots. Compel Prod. ("Gov't's Reply"), ECF No. 14 (No. 18-175). Each bank was permitted to file a sur-reply, and each of those, with more attachments, was submitted on February 26, 2019. See generally Bank One's Sur-Reply Opposing Mot. Compel ("Bank One's Sur-Reply"), ECF No. 18 (No. 18-175); Bank Two's Sur-Reply Opposing Mot. Compel ("Bank Two's Sur-Reply"); ECF No. 12 (No. 18-176); Bank Three's Sur-Reply Opposing Mot. Compel ("Bank Three's Sur-Reply"), ECF No. 12 (No. 18-177). In support of the banks, the Chinese Ministry of Justice ("MOJ") submitted two letters addressed to the Court. See, e.g. , Bank One's Opp'n, Ex. 3, Jan. 6, 2019 MOJ Ltr., ECF No. 6-3 (No. 18-175); Bank One's Sur-Reply, Ex. 3, Feb. 26, 2019 MOJ Ltr., ECF No. 18-4 (No. 18-175). Following a March 5, 2019 hearing with the government and all three banks, the government and two of the banks-Bank One and Bank Two-were permitted to submit supplemental briefing on a personal jurisdiction issue specific to each bank. The government's supplemental briefs were filed on March 8, 2019, see Gov't's Suppl. Br. Personal Jurisdiction-Bank One ("Gov't's Suppl.-Bank One"), ECF No. 29 (No. 18-175); Gov't's Suppl. Br. Personal Jurisdiction-Bank Two ("Gov't's Suppl.-Bank Two"), ECF No. 25 (No. 18-176), and each bank's response was filed on March 12, 2019, see Bank One's Suppl. Br. Personal Jurisdiction ("Bank One's Suppl."), ECF No. 30 (No. 18-175); Bank Two's Suppl. Br. Personal Jurisdiction ("Bank Two's Suppl."), ECF No. 26 (No. 18-176). Upon consideration of this weighty record, and for the following reasons, each of the government's three motions is granted. I. BACKGROUND The three subpoenas in this matter pertain to an investigation into [REDACTED]. See Gov't's Mot.-Bank One at 1 ; Gov't's Mot.-Bank Three at 1. As noted, [REDACTED] was a Hong Kong based front company for North Korea's [REDACTED]. Gov't's Reply, Ex. 1, Decl. of Special Agent of the Federal Bureau of Investigation ("FBI Decl.") ¶ 9, ECF No. 14-1 (No. 18-175). The now-defunct front company purportedly was established by [REDACTED], a North Korean national, and [REDACTED], a Chinese national. Id. A. [REDACTED] Transactions for [REDACTED] Between October 2012 and January 2015, [REDACTED] used [REDACTED] for United States dollar transactions totaling $ 105,339,483.59. Gov't's Mot.-Bank One at 2; accord Gov't's Mot.-Bank Three at 2. Of that money, $ 45,779,669.50 traveled through a United States correspondent bank account of Bank One, which is a Chinese bank with [REDACTED] United States branches. Gov't's Mot.-Bank One at 2-3; Bank One's Opp'n at 1. The Chinese government, or its affiliated enterprises, own [REDACTED] of Bank One. See Bank One's Opp'n at 17 n.13; see also Gov't's Reply, Ex. 2, Decl. of Professor of Law at George Washington University Law School ("Gov't's Expert Decl.") ¶ 99, ECF No. 14-2 (No. 18-175). Another $ 1,627,909.34 went through a correspondent bank account of Bank Two, which also is a Chinese Bank with a United States branch. Gov't's Mot.-Bank One at 2-3; Bank Two's Opp'n at 4. The Chinese government has a [REDACTED] ownership stake in Bank Two. Gov't's Expert Decl. ¶ 100. Finally, $ 57,931,904.75 was shuttled through a United States correspondent account of Bank Three, which is a Chinese bank without any United States branch, but which maintains [REDACTED] correspondent accounts in the United States. Gov't's Mot.-Bank Three at 2-3; Bank Three's Opp'n, Decl. of General Manager of [REDACTED] for Bank Three ("Bank Three GM Decl.") ¶¶ 7, 10, ECF No. 4-2 (No. 18-177). At least [REDACTED] of Bank Three's publicly traded shares are held by the Chinese government. Id. ¶ 9. Many of these transactions were made after the Treasury Department's Office of Foreign Assets Control ("OFAC"), on [REDACTED], "designated" the [REDACTED] pursuant to Executive Order 13382. See Actions Taken Pursuant to Executive Order 13382, [REDACTED]. Executive Order 13382 authorizes the Secretary of State, the Secretary of Treasury, or "other relevant agencies," to designate, after consulting with their counterpart and the Attorney General, any individual or entity as having engaged "in activities or transactions that have materially contributed to, or pose a risk of materially contributing to, the proliferation of weapons of mass destruction or their means of delivery," as having "provided, or attempted to provide, financial, material, technological or other support for" any such transaction, or as being "owned or controlled by, or acting or purporting to act for or on behalf of" any already-designated individual or entity. See Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters, Exec. Order 13382, 70 Fed. Reg. 38567 (July 1, 2005). As a designated entity, the [REDACTED]'s property interests in the United States are blocked, meaning that the [REDACTED]'s property may not be "transferred, paid, exported, withdrawn, or otherwise dealt in." Id. ; see also 31 C.F.R. § 544.201. Designated entities may apply to OFAC for a license exempting certain property from being blocked. 31 C.F.R. §§ 501.801 - 808, 504.501-508. Based on [REDACTED]'s transactions through the United States financial market, the government is investigating [REDACTED] for three crimes: (1) money laundering, in violation of 18 U.S.C. § 1956 ; (2) violating an order issued under the International Economic Emergency Powers Act, such as Executive Order 13382, which is a violation of 50 U.S.C. § 1705 ; and (3) violating the Bank Secrecy Act. See Gov't's Mot.-Bank One at 4-5; accord Gov't's Mot.-Bank Three at 5. B. The Investigatory Subpoenas In aid of that investigation, on December 26, 2017 the United States Attorney for the District of Columbia sent Bank Three a subpoena under 31 U.S.C. § 5318(k)(3). See Bank Three GM Decl., Ex. 1, Admin. Subpoena, ECF No. 4-2 (No. 18-177). That statutory provision authorizes the Secretary of the Treasury and the Attorney General to "issue a summons or subpoena to any foreign bank that maintains a correspondent account in the United States and request records related to such correspondent account, including records maintained outside of the United States relating to the deposit of funds into the foreign bank." 31 U.S.C. § 5318(k)(3)(A)(i). The subpoena sent to Bank Three sought all records, including "(a) signature cards; (b) documentation of account opening; (c) account ledger cards; (d) periodic account statements; (e) due diligence (including invoices); and (f) records (copied front and back) of all items deposited, withdrawn, or transferred," "from January 1, 2012, through the present," "relating to correspondent banking transactions for [REDACTED]" and "relating to correspondent banking transactions" for a specified account thought to be used by [REDACTED]. See Admin. Subpoena. The next day, Bank One's and Bank Two's local branch each received identical grand jury subpoenas. See Gov't's Mot.-Bank One at 5; see also Bank One's Opp'n, Ex. 1, Grand Jury Subpoena, ECF No. 6-1 (No. 18-175). Those subpoenas commanded that a representative of each bank appear to testify before the grand jury, and bring before the grand jury records, including "(a) signature cards; (b) documentation of account opening; (c) account ledger cards; (d) account statements; (e) due diligence (including invoices); and (f) records (copied front and back) of all items deposited, withdrawn, or transferred," dated between January 1, 2012 and December 26, 2017, related to any account belonging to [REDACTED] or related to a specific account believed to be associated with [REDACTED]. See Grand Jury Subpoena. C. Negotiating Alternatives to the Subpoenas In January 2018, representatives from Bank Three met with the China Banking Regulatory Commission ("the Commission") and the People's Bank of China ("People's Bank"), which together regulate Chinese banking, about the subpoena and were told that the only way under Chinese law that the bank could comply was through the process established under the Agreement Between the Government of the United States of America and the Government of the People's Republic of China on Mutual Legal Assistance in Criminal Matters ("MLAA"), June 19, 2000. See Bank Three GM Decl. ¶¶ 18-20. In March 2018, Bank Three representatives again met with Chinese officials, including officials from the Commission, the People's Bank, and the MOJ, the latter of which is designated under the MLAA as the Chinese authority responsible for MLAA communications. See Bank Three GM Decl. ¶ 20; MLAA Art. 2. The Chinese authorities repeated that Bank Three should ask the United States government to request the subpoenaed records through the MLAA process and informed Bank Three that the MOJ would respond quickly to an MLAA request. Bank Three GM Decl. ¶¶ 20a, 20b. The MOJ's advice was memorialized in a March 22, 2018 letter sent to Bank Three, which relayed that the MOJ would timely review and handle an MLAA request. Bank Three GM Decl., Ex. 2, Mar. 22, 2018 MOJ Ltr., ECF No. 4-2 (No. 18-177). The same letter explained that if Bank Three "provide[s] relevant client information to the U.S. DOJ directly, the banking regulatory authorities will impose administrative penalties and fines on you, and you may bear civil or criminal liabilities depending on your situation." Id. Still in March 2018, United States counsel for Bank Three shared the MOJ's letter with, and sent a letter on behalf of Bank Three, to the United States government explaining that Bank Three had been advised that under Chinese law, the MLAA is the exclusive vehicle for the bank to produce the requested records. Bank Three GM Decl. ¶ 23; Bank Three's Opp'n, Decl. of Bank Three's U.S. Counsel ("Bank Three U.S. Counsel Decl."), Ex. 3, Mar. 23, 2018 U.S. Counsel Ltr., ECF No. 4-1 (No. 18-177). Bank Three's counsel assured the United States government that the MOJ "would quickly respond to such a [MLAA] request" and that the bank was "ready and willing to provide [the records] to MOJ," Mar. 23, 2018 U.S. Counsel Ltr. at 1, having taken steps to preserve the requested records, id. at 2. Bank One claims to have expressed a willingness to facilitate an MLAA request around the same time. Bank One's Opp'n at 3-4. Additionally, Bank Two "has given its assurances that it will produce the requested documents within days of a request through the MLAA." Bank Two's Opp'n at 16. Following these communications, a delegation from the Department of Justice visited China-once in April 2018 and again in August 2018-to discuss "China's repeated failure to respond to MLAA requests-which necessitated the United States to proceed through Bank of Nova Scotia subpoenas and other authorities under U.S. law." Gov't's Reply, Ex. 3, Decl. of Associate Director of the Office of International Affairs of Department of Justice's Criminal Division ("DOJ Decl.") ¶ 17, ECF No. 14-3 (No. 18-175). These discussions did not result in the production of the requested documents. D. The Government's Motions to Compel As already outlined, in November 2018, the United States government filed a motion to compel compliance with each of the three subpoenas. See generally Gov't's Mot.-Bank One; Gov't's Mot.-Bank Two; Gov't's Mot.-Bank Three. Briefing continued through the end of February 2019, at which time the banks all filed a sur-reply. See generally Bank One's Sur-Reply; Bank Two's Sur-Reply; Bank Three's Sur-Reply. While briefing was underway, the MOJ sent two letters to the Court. In the first, the MOJ committed to "timely review and handle the requests for assistance sought by DOJ in accordance with the [MLAA] and applicable domestic law. For the request in line with the [MLAA], China will provide the assistance to the United States accordingly." See, Jan. 6, 2019 MOJ Ltr. at 4. In the second, the MOJ restated that "if the DOJ makes a MLA[A] request in the present case, the MOJ will promptly review and process it. To be more specific, if such a US request complies with the applicable provisions of the [Law of the People's Republic of China on International Legal Assistance in Criminal Matters] and the MLAA, the MOJ will promptly transfer the request to Competent Authorities of China for further review and execution." Feb. 26, 2019 MOJ Ltr. at 3. On March 5, 2019, the Court held a hearing with all three banks. Following the hearing, the government, Bank One, and Bank Two submitted supplemental briefing about whether those two banks, in the process of seeking authorization from the Board of Governors of the Federal Reserve System ("Federal Reserve") to open United States branches, had filed a consent to personal jurisdiction that covered this matter. See generally Gov't's Suppl.-Bank One; Gov't's Suppl.-Bank Two; Bank One's Suppl.; Bank Two's Suppl. With the briefing and hearing now complete, the motions are ripe for resolution. II. LEGAL STANDARD If compliance with a grand jury subpoena "would be unreasonable or oppressive," a court may quash or modify the subpoena. FED. R. CRIM. P. 17(c)(2). A subpoena might be unreasonable or oppressive if compliance would violate foreign law. In re Grand Jury Subpoena , 912 F.3d 623, 633 (D.C. Cir. 2019). Issues of foreign law are questions of law and, as the parties relying on foreign law, the banks must show that Chinese law would prevent compliance with the court's order. Id. (citing In re Sealed Case , 825 F.2d 494, 498 (D.C. Cir. 1987) ); see also United States v. R. Enterprises, Inc. , 498 U.S. 292, 301, 111 S.Ct. 722, 112 L.Ed.2d 795 (1991) ("[A] grand jury subpoena issued through normal channels is presumed to be reasonable, and the burden of showing unreasonableness must be on the recipient who seeks to avoid compliance."). As for the administrative subpoena, the court's role "is a strictly limited one." Resolution Tr. Corp. v. Thornton , 41 F.3d 1539, 1544 (D.C. Cir. 1994). Courts "consider only whether 'the inquiry is within the authority of the agency, the demand is not too indefinite and the information sought is reasonably relevant.' " Id. (quoting United States v. Morton Salt Co. , 338 U.S. 632, 652, 70 S.Ct. 357, 94 L.Ed. 401 (1950) ). "Accordingly, a court must look to the authorizing statute in determining whether a given subpoena may be enforced." United States v. Apodaca , 251 F.Supp.3d 1, 8 (D.D.C. 2017) ; see also United States v. Newport News Shipbuilding & Dry Dock Co. , 837 F.2d 162, 165-66 (4th Cir. 1988) ("Here, the subpoena is deficient because it exceeds the proper scope of DCAA's statutory authority."). Yet, the Court's inquiry "is neither minor nor ministerial." Resolution Tr. Corp. , 41 F.3d at 1544. III. DISCUSSION The government's motions to compel compliance present two principle issues: First, whether the subpoenas are enforceable, which, in turn, depends on whether the banks are subject to this Court's jurisdiction and whether the subpoena issued to Bank Three exceeds the government's authority under 31 U.S.C. § 5318. Second, even if the subpoenas are enforceable against the three banks, whether such enforcement is reasonable, as a matter of international comity. Those issues are addressed in that order. A. Personal Jurisdiction To direct an entity, or its representative, to come before a grand jury, the district court must have personal jurisdiction over the entity. In re Sealed Case ("Sealed Case II "), 832 F.2d 1268, 1272 (D.C. Cir. 1987) abrogated on other grounds by Braswell v. United States, 487 U.S. 99, 108 S.Ct. 2284, 101 L.Ed.2d 98 (1988). That limitation on a court's authority to proceed against a party enforces the Constitution's Due Process Clauses. Goodyear Dunlop Tires Operations, S.A. v. Brown , 564 U.S. 915, 923, 131 S.Ct. 2846, 180 L.Ed.2d 796 (2011). As explained below, each bank is subject to the personal jurisdiction of this Court because both Bank One and Bank Two have consented to the exercise of such jurisdiction and, even if those two banks had not given consent, all three banks have sufficient minimum contacts with the relevant forum, which here is the United States, for the exercise of such jurisdiction. 1. Consent to Jurisdiction by Bank One and Bank Two For two of the banks-Bank One and Bank Two-personal jurisdiction is straightforward: each has consented to personal jurisdiction. Those two banks, while applying to the Federal Reserve to open a branch in the United States, "consent[ed] to the jurisdiction of the federal courts of the United States and of all United States governmental agencies, departments and divisions for purposes of any and all claims made by, proceedings initiated by, or obligations to, the United States, the Board, and any other United States governmental agency, department or division, in any matter arising under U.S. Banking Law." Gov't's Suppl.-Bank One, Ex. A., Consent to Jurisdiction-Bank One at 1, ECF No. 29-1 (No. 18-175); accord Gov't's Suppl.-Bank Two, Ex. A., Consent to Jurisdiction-Bank Two, ECF No. 25-1 (No. 18-176). Each consent expressly defines "U.S. Banking law" to include, among other things, the Bank Secrecy Act. See Consent to Jurisdiction-Bank One at 2-3 n.2; Consent to Jurisdiction-Bank Two at 1-2 n.2. Those consents apply here, the government argues, because the subpoenas have been issued in conjunction with an investigation into possible violations of the Bank Secrecy Act, namely: 31 U.S.C. § 5318. Gov't's Suppl.-Bank One at 3-4; Gov't's Suppl.-Bank Two at 3-4. Bank One argues that consent to the "jurisdiction of the federal courts of the United States" does not mean what it says, but rather means "consent to the jurisdiction of some federal court (e.g., a federal court having a connection to the matter at issue) though not necessarily any and every federal court." Bank One's Suppl. at 4 (emphasis in original). The limitation that Bank One tries to read into the consent does not exist. Additionally, in this case, for reasons explained in Section III.A.2, infra , federal judicial districts cannot be distinguished for purposes of personal jurisdiction. Bank Two, for its part, tries to avoid the consent by arguing that the Bank Secrecy Act cannot apply here because [REDACTED] is not a financial institution under the Bank Secrecy Act, the Bank Secrecy Act does not apply extraterritorially to an entity, like [REDACTED], without United States operations, and the consent should be read as limited only to instances in which the bank itself is accused of wrongdoing. Bank Two's Suppl. at 6-7. Bank Two's arguments elide too much context. First, [REDACTED] is not the only subject of the investigation. [REDACTED] is another. Second, the government's investigation is still before the grand jury. At this stage, the government need not prove violations of the Bank Secrecy Act, or who may have violated the statute, for the enforcement action to arise under United States banking law. "[T]o establish jurisdiction for purposes of enforcing a grand jury subpoena, the [government] need not prove what would be necessary to confer jurisdiction over the companies for purposes of trial.... [S]o stringent a requirement 'might well invert the grand jury's function, requiring that body to furnish answers to its questions before it could ask them." Sealed Case II , 832 F.2d at 1274 (quoting In re Grand Jury Proceedings (Harrisburg Grand Jury 79-1) , 658 F.2d 211, 214 (3d Cir. 1981) ); accord In re Grand Jury Subpoena , 912 F.3d at 632 ; see also In re M.H. , 648 F.3d 1067, 1071 (9th Cir. 2011) ("M.H. argues that-for a number of reasons-[a Bank Secrecy Act regulation] does not apply to him, so he is not required to comply with the grand jury's subpoena.... But at this point in its investigation, the Government need not prove the regulation or the [Bank Secrecy Act] apply."). Finally, nowhere does the consent's text suggest that the bank must itself be the entity investigated for violating United States banking law. Simply put, the motions to compel are "proceedings initiated by ... the United States ... in [a] matter arising under U.S. Banking law." In short, both Bank One and Bank Two have expressly consented to the exercise of personal jurisdiction in this proceeding. 2. Each Bank Has Sufficient Minimum Contacts with the Relevant Forum for the Exercise of Personal Jurisdiction If, however, the consent forms are ineffectual, Bank One and Bank Two are on similar footing as Bank Three, which has never has submitted any consent to the Federal Reserve. In that case, personal jurisdiction over the banks may take one of two forms: "general or all-purpose jurisdiction" or "specific or case-linked jurisdiction." Goodyear , 564 U.S. at 919, 131 S.Ct. 2846. Here, the government argues only that the banks are subject to specific personal jurisdiction in this Court. Gov't's Mot.-Bank One at 9-10 n.7; Gov't's Mot.-Bank Three at 10 n.9. Specific personal jurisdiction has two prerequisites: the entity must have "[1] certain minimum contacts with [the forum] such that [2] the maintenance of the suit does not offend traditional notions of fair play and substantial justice." Daimler AG v. Bauman , 571 U.S. 117, 126, 134 S.Ct. 746, 187 L.Ed.2d 624 (2014). A court may exercise specific jurisdiction over an entity only as to matters that "aris[e] out of or relat[e] to the defendant's contacts with the forum. " Bristol-Myers Squibb Co. v. Superior Court of Cal., S.F. Cty. , --- U.S. ----, 137 S.Ct. 1773, 1780, 198 L.Ed.2d 395 (2017) (emphasis in original). "In other words, there must be 'an affiliation between the forum and the underlying controversy, principally, [an] activity or an occurrence that takes place in the forum State and therefore is subject to the State's regulation." Id. (quoting Goodyear , 564 U.S. at 919, 131 S.Ct. 2846 ). Each of the three banks contests that the necessary contacts with District of Columbia are present and therefore each contends that being subjected to jurisdiction in the District of Columbia is unfair. The government considers the banks' focus on the District of Columbia as misplaced since the relevant forum for consideration of personal jurisdiction is the United States as a whole. Gov't's Mot.-Bank One at 10; Gov't's Mot.-Bank Three at 10. The Court is persuaded that the government is correct and that the banks' contacts with the United States are the measure of whether personal jurisdiction may be exercised here. a) Defining the Relevant Forum The first step in determining whether a party has adequate contacts for personal jurisdiction is identifying the forum with which the contacts must be assessed. For a case subject to the Fourteenth Amendment's Due Process Clause, personal jurisdiction depends on the party's "relationship to the forum State." Bristol-Myers Squibb , 137 S. Ct. at 1779. Conversely, for a case governed by the Fifth Amendment's Due Process Clause, the relevant forum is the United States. Livnat v. Palestinian Authority , 851 F.3d 45, 54-55 (D.C. Cir. 2017). As the D.C. Circuit explained in Livnat , "[t]he only difference in the personal-jurisdiction analysis under the two Amendments is the scope of the relevant contacts: Under the Fourteenth Amendment, which defines the reach of state courts, the relevant contacts are state-specific. Under the Fifth Amendment, which defines the reach of federal courts, contacts with the United States as a whole are relevant." Id. at 55 (emphasis in original). Which constitutional amendment governs depends on how service may be accomplished. See Livnat , 851 F.3d at 54 (explaining that the constitutional analysis was governed by Fifth Amendment because Federal Rule of Civil Procedure 4(k)(2), rather than Rule 4(k)(1), applied). When the "court exercises personal jurisdiction by virtue of a federal statute authorizing nationwide service of process" the Fourteenth Amendment, and thus the "requirement of 'minimum contacts' with a forum state is inapplicable." S.E.C. v. Bilzerian , 378 F.3d 1100, 1106 n.8 (D.C. Cir. 2004). Instead, the Fifth Amendment applies. Livnat , 851 F.3d at 54 ; see also Abelesz v. OTP Bank , 692 F.3d 638, 655-56 (7th Cir. 2012) ("Plaintiffs have attempted to support general personal jurisdiction over MKB and OTP by examining all of their contacts with the United States as a whole.... Under Rule 4(k)(2) of the Federal Rule of Civil Procedure, plaintiffs may do so, at least regarding their claims arising under federal or international law."); United Elec. v. 163 Pleasant Street Corp. , 960 F.2d 1080, 1085 (1st Cir. 1992) ("When a district court's subject matter jurisdiction is founded upon a federal question, the constitutional limits of the court's personal jurisdiction are fixed, in the first instance, not by the Fourteenth Amendment but by the Due Process Clause of the Fifth Amendment."); Wultz v. Islamic Republic of Iran ("Wultz I "), 755 F.Supp.2d 1, 32 (D.D.C. 2010) (ruling that the Fifth Amendment governed personal jurisdiction for case brought under Antiterrorism Act, which includes a national-service-of-process provision). The Fifth Amendment controls here, the government contends, because the Court's power to enforce the three subpoenas derives from federal authority permitting nationwide service of process. See Gov't's Mot.-Bank One at 10 ("When considering specific personal jurisdiction under a federal statute that allows for nationwide service, such as a grand jury subpoena, the forum for which a court examines the party's contacts is the entire United States, rather than a specific district."); Gov't's Mot.-Bank Three at 10 ("When considering specific personal jurisdiction under a federal statute that allows for nationwide service, such as an administrative subpoena issued pursuant to 31 U.S.C. § 5318(k)(3), the forum for which a court examines the party's contact is the entire United States, rather than a specific district."). The merits of the government's position are considered first for the grand jury subpoenas and second for the administrative subpoena. i) Grand Jury Subpoenas Bank One's and Bank Two's initial opposition briefs each challenged being subject to this Court's exercise of personal jurisdiction, but, at best, each ignored that the United States might be the relevant forum for minimum contacts. Bank One conceded "avail[ing] itself of the U.S. banking system to process certain transactions," but argued that availment did not matter for personal jurisdiction because "the discovery sought in the Subpoena is not limited to those transactions...." Bank One's Opp'n at 6. In certain respects, Bank One's brief actually signaled agreement that the relevant forum is the United States. See Bank One's Opp'n at 4-5 ("In cases involving the enforcement of a grand jury subpoena, courts need not look to a state's long-arm statute when the subject of a grand jury's investigation is the possible violation of federal statutes."). Similarly, Bank Two contested this Court's jurisdiction because the bank's contact with the District of Columbia is incidental to the records sought. Bank Two's Opp'n at 38-39. As an initial matter, then, these two banks have waived any argument against the United States being the relevant forum. In re Asemani , 455 F.3d 296, 300 (D.C. Cir. 2006) ("Asemani's first argument ... is waived because it was made for the first time in his reply brief."). Only in their sur-replies did Bank One and Bank Two offer a response to the government's contention that the jurisdictional forum is the United States. Even indulging those belated arguments, they fail on the merits. In its sur-reply, Bank One notes that the government is investigating possible violations of 18 U.S.C. § 1956, 50 U.S.C. § 1705, and 31 U.S.C. § 5318, and that none of those three statutes permits nationwide service of process. Bank One's Sur-Reply at 3. Similarly, Bank Two argues that "to the extent that the Government can identify applicable federal criminal statutes that permit nationwide services of process, it still would need to demonstrate that these statutes permit the exercise of jurisdiction over non-parties who are not accused of having violated the statutes." Bank Two's Sur-Reply at 11. Those criminal statutes, however, are irrelevant. This is an action to enforce subpoenas and, thus, jurisdiction depends on whether the subpoenas may be served nationwide. See Gucci America Inc. v. Weixing Li ("Gucci II "), 768 F.3d 122, 142 n.21 (2d Cir. 2014) (identifying Federal Rule of Civil Procedure 45(b)(2)'s national service provision as the relevant authority for whether jurisdiction depends on contacts with the entire United States); see also In re Sealed Case , 141 F.3d 337, 340-41 (D.C. Cir. 1998) (determining jurisdiction to transfer a motion to quash a civil subpoena based on text of Federal Rule of Civil Procedure 45 ). Relegated to a single sentence of a footnote, see Bank One's Sur-Reply at 4 n.2, Bank One conveys an understanding that jurisdiction here does not turn on the specific crimes the grand jury is investigating, but rather is a function of Federal Rule of Criminal Procedure 17, which governs federal grand jury subpoenas, see Dep't of Justice Manual § 9-11.140 ("Subpoenas in Federal proceedings, including grand jury proceedings, are governed by Rule 17 of the Federal Rule of Criminal Procedure."). Under that procedural rule, "[a] subpoena requiring a witness to attend a hearing or trial may be served at any place within the United States." FED. R. CRIM. P. 17(e). Plainly, a grand jury subpoena may be served nationwide. Still, Bank One maintains that Federal Rule of Criminal Procedure 17(e) does not apply here because that rule "allow[s] nationwide service only for subpoenas to compel attendance at a hearing or trial." Bank One's Sur-Reply at 4 n.2. Bank One's argument is bewildering because the subpoena Bank One received was a "Subpoena to Testify before a Grand Jury," which commanded a witness "to appear in this United States district court at the time, date, and place shown below." See Grand Jury Subpoena. While the subpoena also required the witness to bring documents, id. , a criminal subpoena may include such an order. See FED. R. CRIM. P. 17(c). In the end, compelling Bank One to comply might result only in the production of documents, but that is true only as a matter of courtesy. The government's cover letter, sent with the subpoena, communicated that, "if it is more convenient for you, you may send the requested records to the undersigned United States Attorney in lieu of personally appearing before the Grand Jury on the date indicated." See Bank One's Opp'n, Ex. 1, Grand Jury Subpoena Ltr., ECF No. 6-1 (No. 18-175). At bottom, Federal Rule of Criminal Procedure 17(e) allows for the grand jury subpoena that Bank One and Bank Two each received to be served nationwide. Therefore, personal jurisdiction depends on each banks' contacts with the United States. ii) Administrative Subpoena Like Bank One and Bank Two, Bank Three's initial opposition brief gave short-shrift to the possibility that the relevant jurisdictional forum is the United States. While Bank Three spent several pages discounting its contact with the District of Columbia, see Bank Three's Opp'n at 11-15, the bank spent just a single footnote attacking that personal jurisdiction to enforce an administrative subpoena that can be served nationwide depends on national contacts, id. at 15 n.4. D.C. Circuit precedent, Bank Three insisted, did not support the government's position. Id. On that front, Bank Three is wrong. See Bilzerian , 378 F.3d at 1106 n.8 ("The Circuit has held that the requirement of 'minimum contacts' with a forum state is inapplicable where the court exercises personal jurisdiction by virtue of a federal statute authorizing nationwide service of process.... In such circumstances, minimum contacts with the United States suffice.") (citing Briggs v. Goodwin , 569 F.2d 1, 8-10 (D.C. Cir. 1977) rev'd sub nom. on other grounds, Stafford v. Briggs, 444 U.S. 527, 100 S.Ct. 774, 63 L.Ed.2d 1 (1980) ); see also Bricklayers & Trowel Trades Int'l Pension Fund v. Kel-Tech Constr., Inc. , 319 F.Supp.3d 330, 339 (D.D.C. 2018) (citing Bilzerian for same conclusion); Bally Gaming, Inc. v. Kappos , 789 F.Supp.2d 41, 45-46 (D.D.C. 2011) (same). In light of this precedent, Bank Three's sur-reply changes course, arguing that 31 U.S.C. § 5318(k)(3)(A) "does not expressly authorize nationwide service." Bank Three's Sur-Reply at 20 (emphasis in original). That tardy argument is waived. In re Asemani , 455 F.3d at 300 ("Asemani's first argument ... is waived because it was made for the first time in his reply brief."). Even if not waived, the argument Bank Three advances is unpersuasive. A subpoena under 31 U.S.C. § 5318(k)(3)(A)(ii) may be served "on the foreign bank in the United States if the foreign bank has a representative in the United States." That text does not introduce geographic limits on where in the United States service may be accomplished. True, service may be accomplished in the United States only "if the foreign bank has a representative in the United States," but that language is not meaningfully restrictive as all foreign banks that maintain a correspondent account in the United States "shall maintain ... the name and address of a person who resides in the United States and is authorized to accept service of legal process for records regarding the correspondent account." 31 U.S.C. § 5318(k)(3)(B)(i). That provision permits the representative to reside anywhere in the United States. Thus, together, the statute requires that all foreign banks with a correspondent account in the United States must have a representative in the United States, and service may be accomplished wherever that representative is stationed. Comparing 31 U.S.C. § 5318(k)(3) against other parts of the same section, in Bank Three's view, reinforces the bank's restrictive reading. Bank Three's Sur-Reply at 21. Just the opposite is true. Under 31 U.S.C. § 5318(a)(3), (4), the Secretary of Treasury may summon the representative of a financial institution to appear and produce a subset of the institution's financial records. That summons "may require that books, papers, records, or other data stored or maintained at any place be produced at any designated location in any State or in any territory or other place subject to the jurisdiction of the United States not more than 500 miles distant from any place where the financial institution or nonfinancial trade or business operates or conducts business in the United States." 31 U.S.C. § 5318(c)(1). Thus, Congress expressly limited service provisions elsewhere in the statute. Similar territorial limits are notably absent from 31 U.S.C. § 5318(k)(3), reflecting an intended broader reach. Elsewhere in the statute, the Attorney General is authorized to initiate compliance proceedings against a financial institution's representative if the financial institution refuses the Secretary of Treasury's summons issued under 31 U.S.C. § 5318(a)(3), (4). Id. § 5318(e). Process for the compliance proceeding "may be served in any judicial district in which such person may be found." Id. § 5318(e)(5). Bank Three sees this text as the sort of express authorization of nationwide service missing from 31 U.S.C. § 5318(k)(3), Bank Three's Sur-Reply at 21, but permitting service in "in any judicial district" is no broader than permitting service "in the United States." Moreover, the statute explicitly confers jurisdiction over the compliance proceeding to the court sitting either where "the investigation which gave rise to the summons is being or has been carried on; the person summoned is an inhabitant; or the person summoned carries on business or may be found." See 31 U.S.C. § 5318(e)(2). Bank Three considers this a "broad jurisdictional provision" and underscores that "no such broad language-indeed, no language specifically addressing personal jurisdiction-exists in Section 5318(k)." Bank Three's Sur-Reply at 21. Yet, Bank Three has turned the actual import of 31 U.S.C. § 5318(e)(2) upside down. Section 5318(e)(2) limits jurisdiction to three districts, despite 31 U.S.C. § 5318(e)(5)'s nationwide service provision. No similar limits were attached to a proceeding to enforce a subpoena under 31 U.S.C. § 5318(k)(3). Thus, Congress provided for nationwide service of a subpoena issued to a foreign bank that maintains a correspondent account in the United States. Personal jurisdiction over Bank Three, like Bank One and Bank Two, depends on the bank's contacts with the United States. b) Minimum Contacts Moving to each bank's United States contacts, personal jurisdiction exists only if each bank has " 'purposefully availed itself of the privilege of conducting activities within the forum State' or [ ] purposefully directed its conduct into the forum States." Bristol-Myers Squibb , 137 S.Ct. at 1785-86 (quoting J. McIntyre Machinery, Ltd. v. Nicastro , 564 U.S. 873, 877, 131 S.Ct. 2780, 180 L.Ed.2d 765 (2011) ). For purposes of jurisdiction to enforce a subpoena, the government need only show "that there is a reasonable probability it will succeed in establishing the fact necessary for the exercise of jurisdiction." Sealed Case II , 832 F.2d at 1274 (quoting Marc Rich & Co. v. United States , 707 F.2d 663, 670 (2d Cir. 1983) ). The government hangs personal jurisdiction here on the banks having "availed themselves of the privileges of conducting transactions in U.S. dollars via correspondent accounts in the United States." Gov't's Mot.-Bank One at 12; accord Gov't's Mot.-Bank Three at 12-13. In particular, between October 2012 and January 2015, [REDACTED] conducted: 323 transactions through Bank One's United States correspondent account, worth $ 45,779,669.50, see Gov't's Mot.-Bank One at 2-3; see also FBI Decl. ¶ 13; 15 transactions through Bank Two's United States correspondent account, worth $ 1,627,909.34, see Gov't's Mot.-Bank One at 2-3; see also FBI Decl. ¶ 13; and 388 transactions through Bank Three's correspondent account, worth $ 57,931,904.75, see Gov't's Mot.-Bank Three at 2-3; see also FBI Decl. ¶ 13. Previously, the D.C. Circuit has described a bank that does "considerable business in the United States" as "plainly [having] the 'minimum contacts' with this country to establish jurisdiction." Sealed Case II , 832 F.2d at 1273 n.3. Given that the banks' respective opposition briefs fixated on contacts with the District of Columbia, none disputed that the correspondent banking activity qualifies as purposeful availment of the United States. Instead, to the extent any discussed national contacts, Bank One admitted that it "has availed itself of the U.S. banking system to process certain transactions." Bank One's Opp'n at 6. Similarly, Bank Two, to create distance from the District of Columbia, highlighted that "[t]o the extent [Bank Two] has any contacts with the United States it is with New York, not Washington D.C." Bank Two's Opp'n at 38. Finally, Bank Three confessed to "maintain[ing] correspondent accounts with banks in the United States, including the account identified in the subpoena, to process U.S. dollar transactions." Bank Three's Opp'n at 4 (citing Bank Three GM Decl. ¶ 10); id. at 14-15 ("The government also suggests that this Court has personal jurisdiction because [Bank Three] has engaged in transactions through its correspondent account in New York.... But those transactions have no nexus to the District of Columbia and thus cannot give rise to personal jurisdiction there."). Of course, since the relevant forum is the United States, each bank's connections with any part of the country suffice. Bank Three cites one case from this district ruling that "[t]he Court ... is at a loss as to how the existence of [correspondent] bank accounts in New York can possibly establish the banks' presence in the District of Columbia. " Bank Three's Opp'n at 14 (quoting Day v. Cornér Bank (Overseas) Ltd. , 789 F. Supp. 2d 150, 156 (D.D.C. 2011) ) (emphasis in original). Cornér Bank is irrelevant twice over. First, the quoted passage pertained to general jurisdiction. Cornér Bank , 789 F.Supp.2d at 155-57. That same distinction renders two other cases Bank Three cites inapt. See In re Terrorist Attacks on Sept. 11, 2001 , 714 F.3d 659, 680 (2d Cir. 2013) ("Furthermore, we conclude that the alleged use of correspondent bank accounts and the maintenance of a website that allows account holders to manage their accounts are insufficient to support the exercise of general personal jurisdiction over NCB."); Abelesz , 692 F.3d at 658 ("[M]any courts have soundly rejected the suggestion that a correspondent banking relationship is sufficient to support general jurisdiction over a foreign defendant."). Second, in Cornér Bank the Court engaged in a personal jurisdiction analysis under the Fourteenth, rather than the Fifth, Amendment. Cornér Bank, 789 F.Supp.2d at 155 (treating the District of Columbia as the relevant jurisdictional forum); id. at 157 ("Because this case is before the Court based on diversity jurisdiction ... the Court looks to DC's long-arm statute."). Of course, the banks' United States banking activity must relate to the matter over which the Court will exercise jurisdiction. See Bristol-Myers Squibb, 137 S.Ct. at 1786. Without that connection, jurisdiction is missing. See Leibovitch v. Islamic Republic of Iran , 852 F.3d 687, 690 (7th Cir. 2017) (refusing to exercise personal jurisdiction because "subpoenas issued in this case are not tailored to the banks' presence or activities in the United States"); Wultz I , 755 F.Supp.2d at 33-34 (D.D.C. 2010) (distinguishing between banks with knowledge that customer accounts were funding terrorist activity and banks without such knowledge for purposes of personal jurisdiction over banks sued under the Antiterrorism Act); Tamam v. Fransabank Sal , 677 F.Supp.2d 720, 727-28 (S.D.N.Y. 2010) (rejecting specific personal jurisdiction despite correspondent banking activity because the complaint did not allege that any of the defendants transferred money through the correspondent accounts). The opposite, however, also is true: correspondent banking activity suffices for specific personal jurisdiction when the exercise of that jurisdiction pertains to the correspondent banking activity. See Licci ex rel. Licci v. Lebanese Canadian Bank, SAL , 732 F.3d 161, 170-71 (2d Cir. 2013) (concluding that personal jurisdiction existed based on correspondent banking activity when use of correspondent accounts were "part of the principal wrong at which the plaintiffs' lawsuit is directed"); Gucci America, Inc. v. Weixing Li ("Gucci III "), 135 F.Supp.3d 87, 97-99 (S.D.N.Y. 2015) (finding that court had jurisdiction to enforce Rule 45 subpoena against Bank of China for records evidencing conduct directly related to the alleged injury); Correspondent Servs. Corp. v. J.V.W. Inves. Ltd. , 120 F.Supp.2d 401, 405 (S.D.N.Y. 2000) (finding that when correspondent banking activity "is at the very root of the action" it may "give[ ] rise to personal jurisdiction"). Each subpoena in this case seeks records about [REDACTED]'s use of the three banks' correspondent accounts to conduct transactions in the United States. Indeed, [REDACTED]'s use of the United States financial system is "the gravamen of this case." Gov't's Reply at 11. Accordingly, the subpoenas are directly related to the minimum contacts that permit the exercise of jurisdiction. c) Fair Play and Substantial Justice Finally, the exercise of personal jurisdiction over any of the banks must not "offend traditional notions of fair play and substantial justice." Goodyear , 564 U.S. at 923, 131 S.Ct. 2846. Said differently, the parties must have "fair warning that a particular activity may subject them to the jurisdiction of a foreign sovereign." Livnat , 851 F.3d at 48. Whether jurisdiction is fair and just accounts for "the burden on the defendant, the interest of the forum State, and the plaintiff's interest in obtaining relief" as well as "efficient resolution of controversies" and "the procedural and substantive policies of other nations whose interests are affected by the assertion of jurisdiction." Asahi Metal Industry Co., Ltd. v. Superior Court of Cal., Solano Cty. , 480 U.S. 102, 113, 115, 107 S.Ct. 1026, 94 L.Ed.2d 92 (1987). Any party that has constitutionally sufficient contacts with a forum "must present a compelling case that the presence of some other considerations would render jurisdiction unreasonable." Burger King Corp. v. Rudzewicz , 471 U.S. 462, 477, 105 S.Ct. 2174, 85 L.Ed.2d 528 (1985). Generally, the banks advance that the exercise of jurisdiction here would be unfair because the potential upshot of jurisdiction is a burdensome order compelling the production of records that are housed in China, see Bank One's Opp'n at 7, and cannot be disclosed without violating Chinese law, see id. at 8; Bank Two's Opp'n at 38; Bank Three's Opp'n at 16. Imposing such a burden is unnecessary, in the banks' view, given that the MLAA is an efficient alternative, see Bank One's Opp'n at 9-10; Bank Two's Opp'n at 38; Bank Three's Opp'n at 16-17. Additionally, forcing the banks to divulge client information undermines China's interests in a secure banking system, see Bank One's Opp'n at 8, and might lead to reciprocal consequences, Bank Three's Opp'n at 17. None of the banks' own interests, or those of China, match the United States' much stronger interest in the exercise of jurisdiction. Consequently, subjecting the banks to this Court's jurisdiction is, simply put, not unfair. Indeed, two of the banks consented to personal jurisdiction for matters arising under United States banking law. See Consent to Jurisdiction-Bank One; Consent to Jurisdiction-Bank Two. Beyond that, each bank has funneled over a million dollars through the United States on behalf of [REDACTED]. As the Second Circuit has said about such correspondent banking activity, "[i]t should hardly be unforeseeable to a bank that selects and makes use of a particular forum's banking system that it might be subject to the burden of a lawsuit in that forum for wrongs related to, and arising from, that use." Licci , 732 F.3d at 171-72. As another Judge on this Court has held, "[w]ith regard to [Bank of China's] capacity to foresee suit in the District of Columbia, the Court notes that [Bank of China] is a sophisticated international financial institution that plaintiffs allege 'has branches in California and New York, does extensive business throughout the United States[,] and holds significant assets in the United States.' ... As such, it is reasonable to presume that [Bank of China] is fully aware of U.S. law concerning financial institutions...." Wultz I , 755 F.Supp.2d at 34. All the same considerations hold here. Nor would enforcement impose onerous logistical burdens on any of the banks. The government has offered Bank One and Bank Two the option of simply mailing the requested records. See Grand Jury Subpoena Ltr. ("Although you are not required to do so, if it is more convenient for you, you may send the requested records to the undersigned United States Attorney in lieu of personally appearing before the Grand Jury on the date indicated."). Similarly, the administrative subpoena calls only for Bank Three to produce records. Admin. Subpoena ("Compliance can be made by mailing the requested documents via courier...."). None of the banks contends that locating those records will be difficult. To the contrary, Bank Two has given assurances that the requested documents can be collected in days, see Bank Two's Opp'n at 16; Bank Two's Sur-Reply at 3, and Bank Three "took steps to collect and preserve documents" shortly after receiving the subpoena, see Bank Three GM Decl. ¶ 14; accord Mar. 23, 2018 U.S. Counsel Ltr. at 1-2. Bank One estimated that the documents could be collected within 30 days. Mar. 5, 2019 Tr. at 47:3-7, ECF No. 28 (No. 18-175). With the documents already, or easily, collected, now the banks need only put them in the mail, hardly a burden. To the extent that further legal issues will arise from enforcement of the subpoenas, the well-resourced banks are all fully able to ensure adequate representation of their interests. Additionally, for reasons discussed more thoroughly in Section III.C.2, infra , the remainder of the banks' specific arguments are unavailing: the risk that any of the banks will be penalized in China for complying with the subpoenas is overblown; the United States, which seeks these records as part of an investigation into North Korea's nuclear weapons program, does not have an alternative route to obtain them since the MLAA, at least for banking records, is unproductive; and while China does have a legitimate interest in a sound financial system, Chinese law permits the disclosure of banking records in analogous circumstances and therefore appreciates that banking systems do not crumble because the government can obtain some records for law enforcement purposes. * * * * * All told, each bank has purposefully availed itself of the United States financial market through correspondent banking activity, including transactions on behalf of [REDACTED]. The subpoenas are for records related to that activity. Nothing about the exercise of jurisdiction is unjust under those circumstances. B. Statutory Authority for Administrative Subpoena Separate from personal jurisdiction, Bank Three argues that the 31 U.S.C. § 5318(k)(3) subpoena it received is unenforceable because the subpoena goes beyond what the statute permits. In other words, the bank contends that the inquiry is not within the agency's authority. See Resolution Tr. Corp. , 41 F.3d at 1544. Under the USA Patriot Act, Congress authorized the Attorney General and Secretary of Treasury to subpoena records from a foreign bank that maintains a correspondent account in the United States, but only "records related to such correspondent account, including records maintained outside the United States relating to the deposit of funds into the foreign bank." 31 U.S.C. § 5318(k)(3)(a)(i). According to Bank Three, the subpoena in this case, which requests "[a]ll documents relating to correspondent banking transactions for [REDACTED]" as well as "[a]ll documents relating to correspondent banking transactions for" a specific account number, see Admin. Subpoena, "is not restricted to 'records related' to a correspondent account 'in the United States,' but rather appears to address any correspondent account, including accounts located abroad that have no relation to the United States." Bank Three's Opp'n at 33 (emphasis in original); see also Bank Three's Sur-Reply at 4. Bank Three has correspondent accounts in countries other than the United States, and the subpoena covers those accounts too. Bank Three's Sur-Reply at 4. Additionally, Bank Three continues, the subpoena, by encompassing signature cards, account ledgers cards, account statements, and due diligence records for the target account and transactions, is not limited to records related to Bank Three's correspondent account in the United States. Bank Three's Opp'n at 35; Bank Three's Sur-Reply at 4. Two flaws erode the strength of Bank Three's contention. First, the bank's insistence that every record encompassed by the subpoena must itself "relate to" a correspondent bank account in the United States entirely ignores the final clause of 31 U.S.C. § 5318(k)(3)(a)(i), which authorizes subpoenas for "records maintained outside the United States relating to the deposit of funds into the foreign bank." Bank Three cites that clause at the outset of its opposition, see Bank Three's Opp'n at 2, but otherwise ignores it. The bank's sur-reply is no better. See Bank Three's Sur-Reply at 3-6. Indeed, under the disregarded final clause, a subpoena for records revealing the source of funds that [REDACTED] deposited into Bank Three and then funneled through the United States correspondent account, which might include records without a direct tie to the United States account, are accessible. As the government argued at the hearing, the final clause appreciates that "bank records can't be looked at in a vacuum, that money doesn't just appear there.... [T]he flow of funds are related.... [S]o when there is a foreign currency transaction that occurs in China, and that's what infuses the money into the account that illegally sends money here, absolutely that's related." Mar. 5, 2019 Tr. at 92:14-24. Drilling down on the connection, cash deposits, for example, which would be documented in bank statements, are one way [REDACTED] might have funded the accounts used to launder money through the United States. FBI Decl. ¶ 48; see also id. ¶¶ 36-47 (explaining how North Korean front companies smuggle cash to fund payments via correspondent accounts). Intrabank transfers and foreign currency deposits are two other ways. Id. ¶¶ 49-56. Records capturing those deposits are precisely the type that the statute permits the government to subpoena. Second, Bank Three's argument that the subpoena overreaches because it seeks signature cards, account ledgers cards, account statements, and due diligence records, among other records, none which relate to a correspondent account, glosses over "a key feature of the investigation-[REDACTED] solely existed as a front company for [REDACTED]." Gov't's Reply at 29 (citing FBI Decl. ¶¶ 8-10); accord id. at 37. No part of [REDACTED] can be separated from the ploy to put money through the United States financial market. Some of the subpoenaed records-such as signature cards-facilitated that effort, other records-such as ledgers, account statements, and due diligence-evidence aspects of that effort. All, however, relate to the correspondent account or to [REDACTED]'s deposit of funds into its Bank Three account. Only one other court, the District of Oregon, has reviewed whether a subpoena issued under 31 U.S.C. § 5318(k)(3) exceeds the scope of that statute. See United States v. Sedaghaty , No. CR 05-60008-HO, 2010 WL 11643384, at *5-6 (D. Or. Feb. 26, 2010). In Sedaghaty , the government was investigating "allegations of a false tax return and the failure to report money leaving the country." Id. at *1. One defendant allegedly had withdrawn $ 130,000 in traveler's checks and a $ 21,000 cashier's check from a bank in Oregon. Id. That defendant, and one other, then flew to Saudi Arabia, without reporting the currency exiting the country, and cashed the checks in a Saudi bank that had United States correspondent accounts. Id. In the subsequent year's tax return, the withdrawn funds were reported as having been spent on a prayer house or returned to their original source. Id. As part of the related investigation, a subpoena, under 31 U.S.C. § 5318(k)(3), was sent to the Saudi bank for records including, signature cards, customer applications, ledger cards, bank statements, deposits, withdrawals, and those reflecting the cashing of the checks. Id. at *5. The bank objected, contending the records related to the defendant's personal account. Id. at *6. The government, on the other hand, argued that the request related to the defendant's "negotiation of the financial instruments at the center of the investigation" and that those instruments "were issued in U.S. dollars by U.S. banks and that the negotiation of those instruments inevitably related to correspondent accounts in the United States." Id. The court granted the government's motion to compel as to records directly related to the cashing of the cashier's and traveler's checks that had been issued by the United States banks, as well as to bank statements, ledger cards, and information about deposits and withdrawals into the account, but only "to the extent any documents related to the cashier's check and traveler's checks or otherwise to correspondent accounts with United States banks." Id. The motion to compel was not granted as to signature cards and customer applications. Id. While Bank Three prefers that this Court outright deny the motion to compel based on the subpoenas purported overbreadth, see Mar. 5, 2019 Tr. at 89:2-22, curtailing the subpoena, a la Sedaghaty , is the fall back suggestion, id. at 90:6-8. Why the District of Oregon narrowed the subpoena and denied access to signature cards and customer applications, is not explained in the opinion. Two differences between that case and this one, however, jump off the page. There, the bank argued that some of the account records were for the target's personal account, in which case not all records were necessarily related to the correspondent banking activity. To the extent that may have animated the Court's thinking, no similar risk applies here. Additionally, records "related to the deposit of funds into the foreign bank" were not at issue as the investigation involved tracing how already identified financial instruments had been cashed. For each reason, the limits imposed by the Sedaghaty Court should not be imposed here. Accordingly, the subpoena issued to Bank Three is within the authority conferred under 31 U.S.C. § 5318(k)(3)(A)(i). That subpoena can be enforced. C. Comity Authority to enforce the subpoenas is just step one. Step two is whether the court should exercise that authority to enforce the subpoenas. When an enforcement order would create a "true conflict" between domestic and foreign law, the Court should consider, as a matter of international comity, whether to abstain from exercising its authority. See Hartford Fire Ins. Co. v. California , 509 U.S. 764, 798-99, 113 S.Ct. 2891, 125 L.Ed.2d 612 (1993) (ruling that without a "true conflict between domestic and foreign law," there was "no need in this litigation to address other considerations that might inform a decision to refrain from the exercise of jurisdiction on grounds of international comity"); Societe Nationale Industrielle Aerospatiale v. U.S. Dist. Court for S. Dist. of Iowa , 482 U.S. 522, 555, 107 S.Ct. 2542, 96 L.Ed.2d 461 (1987) (Blackmun, J., concurring in part and dissenting in part) ("[T]he threshold question in a comity analysis is whether there is in fact a true conflict between domestic and foreign law. When there is a conflict, a court should seek a reasonable accommodation that reconciles the central concerns of both sets of laws."). The party relying on foreign law