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Sanctions This Week: June 20th – 26th, 2016

 

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On June 20th, 2016, the Office of the Superintendent of Financial Institutions (OSFI) released the United Nations Security Council’s (UNSC’s) Al-Qaida and Taliban Regulations (UNAQTR) update to the sanctions list, removing one individual.

The assets freeze, travel ban and arms embargo, set out in paragraph 2 of Security Council resolution 2253 (2015), no longer apply to the individual.  The review pursuant to Security Council resolution 1822 (2008) was concluded on July 30th, 2009, which is almost seven years ago.  For further information about the process for removing individuals and entities from the UNAQTR List, pursuant to a decision by the UN Security Council Committee, may be found in the “Press Releases” section on the Committee’s website.

Go to OSFI’s release of the UNAQTR update on the OSFI page.

Go to the United Nations Security Council Committee’s page on “Delisting”.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released two updates last week.  One update involved the agreement to to settle potential civil liability for apparent violations of the Iranian Transactions and Sanctions Regulations.  The second update was the addition of a single individual to the Democratic Republic of the Congo Designations list.

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.

The OFAC penalty settlement amount for violations of the Iranian Transactions and Sanctions Regulations was $107,691.30 USD.  The stated violations are as follows:

  • On or about April 15, 2011, the company appeared to have violated the Regulations when it exported 3,600 medical products to its United Arab Emirates distributor with knowledge, or reason to know, that the goods were ultimately destined for Iran; and
  • Additionally, on or about May 27, 2011, the company exported an additional 400 units of the same product to its United Arab Emirates distributor with knowledge, or reason to know, that the goods were ultimately destined for Iran.

OFAC determined that the company voluntarily self-disclosed the apparent violations, and that the company constitutes a non-egregious case. The statutory maximum civil monetary penalty amount for the apparent violations was $1,129,912 USD and the base civil monetary penalty was $159,542.  The settlement amount reflects OFAC’s consideration of the following factors:

  • The company acted willfully by exporting products to its foreign distributor with knowledge, or reason to know, that the exports were ultimately destined for Iran in apparent violation of U.S. law, editing its destination control statement at the request of its distributor, and continuing to conduct business with its distributor after receiving confirmation that the distributor had re-exported the products to Iran;
  • The company’s former CEO and former International Sales Manager knew that the exports were ultimately destined for Iran; and
  • The company did not have a sanctions compliance program in place at the time of the apparent violations.

The company took remedial steps, including the implementation of an OFAC compliance program; and cooperated with OFAC’s investigation and agreed to toll the statute of limitations for a total of 513 days.

See the Enforcement Action Report on OFAC’s website.

See the Democratic Republic of the Congo updates on OFAC’s website.

See OFAC’s recent actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: June 6th – 12th, 2016

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There were no updates released from OSFI this week.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released two updates to five sanction lists last week.  The updates, include the following:

  • Release of the 2015 Terrorist Assets Report;
  • Iran-related FAQ;
  • Counter Terrorism Designation;
  • Termination of the OFAC Fax-on-Demand Service; and
  • Kingpin Act/Honduras and Kingpin Act/Panama-related General Licenses and FAQ.

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.

The 2015 Terrorist Assets Report is theTwenty-fourth Annual Report to the Congress on Assets in the United States Relating to Terrorist Countries and International Terrorism Program Designees.  This report cites a number of sanctions-related authorities including executive orders.  All of the legal materials cited in this report may be found in the legal section of OFAC’s website.

The Iran-related FAQ was adding two FAQs related to Financial and Banking Measures  and nine FAQs related to Foreign Entities Owned or Controlled by U.S. Persons.  OFAC added these FAQs to provide further clarity on the scope of the sanctions lifting that occurred on Implementation Day of the Joint Comprehensive Plan of Action (JCPOA).

The Counter Terrorism Designation list update was related to a single entity, Yarmouk Martyrs Brigade, who are known to be operating in Syria.

The termination of the OFAC Fax-on-Demand services was due to a lack of user demand for the service which is effective Friday, June 10, 2016.  General information pertaining to sanctions programs will remain publicly available on OFAC’s website.

The recently published update and FAQ to the Kingpin Act General Licenses, included four new General Licenses related to:

  • General License 1B – Authorizing certain transactions and activities to liquidate and wind down Banco Continental, S.A.;
  • General License 4B – Authorizing certain transactions involving individuals or entities located in the Panamanian Mall and associated complex, Soho Panama, S.A. (a.k.a. Soho Mall Panama);
  • General License 5A – Authorizing certain transactions and activities related to the Panamanian seizure of Balboa Bank & Trust; and
  • General License 6A – Authorizing certain transactions and activities related to the Panamanian intervention in Balboa Securities, Corp.

These General Licenses authorize certain transactions and activities that would otherwise be prohibited pursuant to the Kingpin Act.  OFAC also amended four FAQs related to the above licenses.

See the 2015 Terrorist Assets Report on OFAC’s website.

See the Iran-related FAQ updates on OFAC’s website.

See the Counter Terrorism Designations list update on OFAC’s website.

See the termination of OFAC’s Fax-on-Demand service information on OFAC’s website.

See the Kingpin Act/Honduras and Kingpin Act/Panama-related General Licenses and FAQs update on OFAC’s website.

See OFAC’s recent actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: May 30th-June 5th, 2016

 

OSFISanctions Pic

There were no updates released from OSFI this week.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released two updates to five sanction lists last week.  The lists that were updated, include the following:

  • Burundi Sanctions Designations;
  • Kingpin Act Designations;
  • Kingpin Act/Panama-related General License; and
  • A Statement on the Felix Maduro Group.

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.

The Burundi Sanctions Designations update included three military individuals, who were added.  These individuals are all high ranking military officers who are currently serving.

The Kingpin Act Designations update, included the removal of a single Panamanian entity.  No details were provided about the reasoning for the removal.

The Kingpin Act/Panama-related General License update, covered the maintenance of certain operations within the country.  Much like the previous related updated, the information provided details how to deal with listed Panamanian individuals and entities included in the General Licenses.  However, this iteration referred to the maintenance of La Estrella and El Siglo Newspapers.

The statement on the Felix Maduro Group, is related to OFAC’s designation of Waked Money Laundering Organization and their shared ownership.  However, based on consultations with, and actions undertaken by, the Government of Panama, OFAC understands that the Government of Panama is working to sever the SDNTs’ ownership and control of the Felix Maduro Group, in an effort to protect the Panamanian and U.S. financial systems from abuse.  The statement further clarifies the persons and transactions that would require authorization.

See the Burundi Sanctions Designations updates on OFAC’s website.

See the Kingpin Act Designations list updates on OFAC’s website.

See the Kingpin Act/Panama-related General License updates on OFAC’s website.

See the Statement on the Felix Maduro Group on OFAC’s website.

See OFAC’s recent actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: May 9th-15th, 2016

OSFISanctions Pic

There were no updates released from OSFI this week.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released two updates to five sanction lists last week.  The lists that were updated, include the following:

  • Kingpin Act Designations;
  • Counter Narcotics Designations;
  • Libya-related Designations;
  • Panama-related and Kingpin Act General Licenses; and
  • An FAQ related to the Panama-related and Kingpin Act General Licenses.

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.

The Kingpin Act and Counter Terrorism Designations updates included, the addition of a single individual (Kingpin Act), who is related to a previous listing, as well as two changes to current listings (Counter Terrorism), based on new information that came to light.

The Libya-related Designation list update included, the addition of a single individual.  The person appended to the list, is the current President and Speaker of the Libyan House of Representatives.

The Panama-related and Kingpin Act General License and FAQ update, covered certain transactions, related to the maintenance of operations within the country.  Specifically, how to deal with listed Panamanian individuals and entities listed in the General Licenses, and called out specific references to the
Soho Mall Panama and Balboa Bank & Trust.  The update follows last week’s release of the FAQ, based on feedback received.

See the Counter Narcotics and Kingpin Act Designation updates on OFAC’s website.

See the Libya-related Designation list updates on OFAC’s website.

See the Panama-related and Kingpin Act General License and FAQ updates on OFAC’s website.

See OFAC’s recent actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: May 2nd-8th, 2016

 

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There were no updates released from OSFI this week.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released two updates to five sanction lists last week.  The lists that were updated, include the following:

  • Counter Narcotics Designations;
  • Panama-related General Licenses;
  • Panama-related and Kingpin Act FAQ;
  • Kingpin Act Designations; and
  • Counter Terrorism Designations.

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.

The changes made to the Counter Narcotics and Kingpin Act Designation lists, all surrounded Colombian nationals and entities.  The update contained the removal of numerous construction companies based in Bogota, and added numerous entities and individuals, who were all Medellin-based.

The Panama-related updates and FAQ release, covered the maintenance of certain operations within the country.  Specifically, how to deal with listed Panamanian individuals and entities, including forms and authorizations that are required prior to any transactions being conducted.  The update adds numerous names, all of whom are currently operating in Panama, which includes companies, such as “Waked Money Laundering Organization.”

See the Counter Narcotics and Kingpin Act Designation updates on OFAC’s website.

See the Panama-related, Counter Terrorism and Kingpin Act Designation updates on OFAC’s website.

See OFAC’s recent actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: April 25th – May 1st, 2016

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There were no updates released from OSFI this week.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released one update to the Belarus-related Executive Order (EO) 13405 sanction list last week.  The original list was replaced and superseded by the new version, which was effective October 30th, 2015.  The EO names nine (9) entities, who are undermining the democratic processes or institutions in Belarus, as well as any entity or individual who directly, or indirectly, owns or controls 50% or more of the listed entities.

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.  The changes to the Belarus-related EO require any U.S. person(s) engaging in transactions involving, directly or indirectly, any of the entities described above, no later than 30 days after the execution of any such transaction in excess of $50,000, or any series of such transactions exceeding $50,000, to file a report with the U.S. Department of State, Office of Eastern European Affairs.  Reports to be filed, must include:

  • The estimated or actual dollar value of the transaction(s), as determined by the value of the goods, services, or contract;
  • The parties involved;
  • The type and scope of activities conducted; and
  • The dates or duration of the activities.

See the Belarus-related Executive Order update on OFAC’s website.

See OFAC’s recent actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: April 18th-24th, 2016

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OSFI

On April 20th, 2016, the Office of the Superintendent of Financial Institutions (OSFI) released the United Nations Security Council’s (UNSC’s) Al-Qaida and Taliban regulations update to the sanctions list, adding five individuals.

The individuals are subject to the assets freeze, travel ban and arms embargo set out in paragraph 2 of Security Council resolution 2253 (2015) adopted under Chapter VII of the Charter of the United Nations.  He individuals listed hold the following titles:

  • Head of religious compliance police and a recruiter of foreign terrorist fighters for Islamic State in Iraq and the Levant (ISIL);
  • lead oil and gas division official of Islamic State in Iraq and the Levant (ISIL);
  • Leader of an Indonesia-based organization that has publicly sworn allegiance to Islamic State in Iraq and the Levant (ISIL);
  • Leader and armed groups in Gaza using money to build an ISIL presence in Gaza; and
  • Served as the acting emir of Jemmah Anshorut Tauhid (JAT) since 2014 and has supported Islamic State in Iraq and the Levant (ISIL).

All of these individuals are of different nationalities, but all have connections to ISIL and have been designated as such.

See the update on the United Nations (UN) website.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released two updates last week.  One update was related to the addition of an individual to the Libya Sanctions list.  The second update was the publication of new Cuba-related Frequently Asked Questions (FAQ), related to the recent changes made to the sanctions that had previously been placed on Cuba.

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.  The changes to the Libya sanctions list included the addition of the Prime Minister and Defense Minister of the National Salvation Government, who has been added due to contributions to the situation in Libya.

See the Cuba-related FAQ update on OFAC’s website.

See the Libya sanction list update on OFAC’s website.

See OFAC’s recent actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: April 4th-10th, 2016

OSFI

There were no updates released from OSFI this week.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released two updates to four sanction lists last week.  The lists that were updated include the following:

  • Counter Narcotics Designations;
  • Iraq-related Designations;
  • South Sudan Designations; and
  • Counter Terrorism designations.

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.  The changes to the Counter Narcotics list included the removal of Caesar’s Park Hotel in Lebanon, and updates to numerous related entities and individuals.

See the Counter Narcotics, Iraq-related and South Sudan Designation updates on OFAC’s website.

See the Counter Terrorism update on OFAC’s website.

See OFAC’s recent actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: March 28th-April 3rd, 2016

 

OSFI

On March 29th, 2016, the Office of the Superintendent of Financial Institutions (OSFI) released the United Nations Security Council’s (UNSC) ISIL (Da’esh) and Al-Qaida sanctions update to the sanctions list, adding a single individual.

The individual is subject to the assets freeze, travel ban and arms embargo set out in paragraph 2 of Security Council resolution 2253 (2015) adopted under Chapter VII of the Charter of the United Nations.  The individual added is Saudi Arabian and holds a Qatari passport.  He is currently residing in Afghanistan and has led an Al-Qaida battalion in Afghanistan since at least mid-2010.Rodney_Money_Clothesline4

See the update on the United Nations (UN) website.

Go to the OSFI lists page.

 

 

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released two updates last week.  One was related to the removal of the Highly Enriched Uranium (HEU) Agreement Assets Control Regulations, and the second, was adding three individuals and two entities to the Counter Terrorism Designations Lists.  OFAC also released the 3rd Quarter FY2014 Report for licensing activities undertaken pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA).

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.  The additions mentioned above, related to the Counter Terrorism Designations update, were included due to the fact both the individuals and entities are linked to Al-Qaida and the Taliban.  They are all Pakistani nationals, with Saudi Arabian ID, and are reported to be currently residing in the UK.

See the Counter-Terrorism update on OFAC’s website.

See OFAC’s recent actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: March 21-27, 2016

Rodney_Money_Clothesline4OSFI

There were no updates released from OSFI this week.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released two updates last week, related to the Zimbabwe, Counter-Terrorism and Non-Proliferation Designation Lists.  A total of three individuals and six entities were added to the respective lists.  OFAC also released the publication of Iran-related General License I and related FAQs.

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.  All of the additions mentioned above were related to aviation, the names added were either connected to an avionics regime, or were the entity under which they were operating.  As for the Iran-related updates, in order to allow for more efficient processing of applications under the Statement of Licensing Policy for Activities Related to the Export or Re-export to Iran of Commercial Passenger Aircraft and Related Parts and Services, OFAC has issued General License I: Authorizing Certain Transactions Related to the Negotiation of, and Entry into, Contingent Contracts for Activities Eligible for Authorization Under the Statement of Licensing Policy for Activities Related to the Export or Re-export to Iran of Commercial Passenger Aircraft and Related Parts and Services.  OFAC also updated the Frequently Asked Questions Relating to the Lifting of Certain U.S. Sanctions under JCPOA.

See the Zimbabwe update on OFAC’s website.

See the Counter-Terrorism and Non-Proliferation update on OFAC’s website.

See OFAC’s recent actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

 

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