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

OSFIOutlier3_032

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  The original list was replaced and superseded by the new version, which was effective October 30th, 2015.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.

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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.

 

Sanctions This Week: February 29-March 6, 2016

OSFI

On March 2nd, 2016, the Office of the Superintendent of Financial Institutions (OSFI) released the United Nations Security Council’s (UNSC) Al-Qaida and Taliban Regulations (UNAQTR) update to the consolidated list, underscoring recent information updates on 11 individuals and one entity.

The 11 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.  The individuals all have different nationalities, locations and expertise, but they have been tied to Al-Qaida.  The entity included is a Moroccan-led terrorist organization formed in August 2013, and were last known to be operating in the Syrian Arab Republic.

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 one update last week, related to North Korea and Non-Proliferation Designation Lists updates.  A total of 11 individuals and five entities were added to both lists.  OFAC also released two updates where information related to two entities was changed.

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 North Korean five entities added are all state-owned entities, who all have North Korean national defense objectives.  The 11 individuals are all high ranking persons within the five organizations.

See the 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: February 22-28, 2016

OSFI

On February 23rd, 2016, the Office of the Superintendent of Financial Institutions (OSFI) released the United Nations Security Council (UNSC) ISIL (Da’esh) and Al-Qaida Sanctions Committee’s update, underscoring recent information updates on five individuals.

The five 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.  All of the updates relate to their most recent known location, 4 of which being, prison.  The final was a ‘last known address’ update for a Tunisian individual, though he was reported as ‘in detention’ in Tunsia, as at December 2009.

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, but both related to settlement of alleged enforcement actions, or civil penalties related to alleged violations of the Cuban Assets Control Regulations (CACR).  The enforcement actions were on two entities, CGG Services S.A., formerly known as CGGVeritas S.A. (CGG France) and Halliburton Atlantic Limited (HAL) on behalf of itself and its affiliate, Halliburton Overseas Limited (HOL).

See OFAC’s recent actions page.

CGG France has agreed to pay $614,250 USD for numerous alleged violations of Cuban Sanctions, when they exported spare parts and other equipment from the United States to M/V Amadeus while the vessel operated in Cuba’s territorial waters.

See the update on OFAC’s website.

The enforcement actions against HAL were for alleged violations of Cuban Sanctions, by dealing in property in which Cuba, or a Cuban national, had an interest when they exported goods and services in support of oil and gas exploration and drilling activities within the Cabinda Onshore South Block oil concession in Angola. HAL knew, or should have known, they were dealing in property in which Cuba had an interest. HAL issued 19 invoices to the Consortium operator Cupet, a company with headquarters in Angola, related to these goods and services, and HAL primarily performed the services which were invoiced. OFAC determined that the alleged violations were voluntarily self-disclosed and constituted a non-egregious case. The total transaction value of the alleged violations was $1,189,752 USD. The statutory maximum civil monetary penalty for the alleged violations was $1,235,000 USD and the base penalty amount for the alleged violations was $423,202 USD.  HAL has agreed to pay $304,706 USD.

See the update on OFAC’s website.

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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