“OFAC Issues New Guidance Regarding Entities Owned by one or More Designated Parties”

August 19, 2014

The National Law Review on August 18, 2014 released the following:

“On August 13, 2014, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new guidance advising that it has changed its policy governing whether entities that are owned by individuals or entities designated under Executive Orders and regulations administered by OFAC, but are not themselves designated, are also subject to U.S. sanctions.

Pursuant to this new guidance, any entity that is owned 50 percent or more in the aggregate, directly or indirectly, by one or more parties on OFAC’s Specially Designated Nationals and Blocked Persons List (“SDN List”) is subject to blocking.1 This is a significant departure from prior OFAC guidance that it was not necessary to aggregate the ownership interests of separate SDN-Listed parties to determine whether a non-listed entity was considered to be blocked.

The new “50 Percent Rule” provides that, effective immediately, the property and interests in property of any entity owned 50 percent or more in the aggregate, directly or indirectly, by persons designated on the SDN List that are, or come into, the United States or the possession of control of a U.S. person are blocked and cannot be dealt in absent licensing or other authorization from OFAC. This means that U.S. persons are effectively prohibited from engaging in any dealings with any entity directly or indirectly owned 50 percent or more in the aggregate by one or more blocked parties regardless of whether such entity is itself designated on the SDN List.

In Frequently Asked Questions (“FAQs”) that OFAC issued on August 14 clarifying the scope of the new 50 Percent Rule, OFAC has provided that this new aggregation test also applies in determining whether entities that are not on the Russian Sectoral Sanctions Identifications (“SSI”) List are subject to the sanctions that apply to the SSI-Listed Russian banks and oil companies. Entities on the SSI List, and entities owned 50 percent or more in the aggregate by such SSI-Listed entities, are not subject to comprehensive blocking measures. Rather, they are subject to a more limited set of restrictions related to new debt with a maturity of longer than 90 days and, in the case of the SSI- Listed banks, new equity, in either case issued by, on behalf of, or for such an entity. For more information on the full scope of SSI List restrictions, please see our prior E-Alert dated July 30, 2014.

THE SCOPE OF THE 50 PERCENT RULE

OFAC’s FAQs offer the following additional guidance concerning the application of the new 50Percent Rule:

1 Certain OFAC sanctions programs are broader and also target entities that are controlled by sanctioned parties. For example, the Iranian Transactions and Sanctions Regulations apply to entities that are owned or controlled by the government of Iran. See 31 C.F.R. §§ 560.304 and 560.313. The 50 Percent Rule’s focus on ownership does not limit the broader scope of these sanctions programs.

The 50 Percent Rule applies only to ownership interests, not control. According to OFAC, “[a]n entity that is controlled (but not owned 50 percent or more) by one or more blocked persons is not considered automatically blocked” pursuant to the 50 Percent Rule. Nonetheless, companies should proceed with caution when considering a transaction with an entity that one or more blocked parties may control because OFAC could add that entity to the SDN List at some point in the future.

Consistent with prior guidance that OFAC has issued, companies should be careful not to negotiate, enter into contracts, or process transactions that involve a blocked person when the blocked person is acting on behalf of a non-blocked entity. OFAC sanctions “prohibit transactions involving, directly or indirectly, a blocked person…even if the blocked person is acting on behalf of a non-blocked entity.” This includes, for example, situations in which a blocked person signs a contract on behalf of a non-blocked entity.

Indirect ownership refers to “ownership of shares of an entity through another entity or entities that are 50 percent or more owned in the aggregate by the blocked person(s).” This means that if Blocked Person X owns 50 percent of Entity A, and Entity A owns 50 percent of Entity B, then both Entity A and B are blocked — Entity A because it is directly owned 50 percent by Blocked Person X and Entity B because it is owned 50 percent by blocked Entity A. Similarly, if Blocked Person X owns 50 percent of Entity A and 10 percent of Entity B, and Entity A also owns 40 percent of Entity B, then Entity B is considered as blocked based on the aggregate 50 percent ownership of Entity B by two blocked parties.

By contrast, indirect ownership does not apply at all where a blocked party owns less than a 50 percent interest in the intermediate entity. Thus, if Blocked Person X owns only 25 percent of Entity A and 25 percent of Entity B, no matter how large an interest Entities A and B hold in Entity C, Entity C will not be considered blocked. This is because Blocked Person X’s 25 percent ownership of each of Entity A and Entity B falls short of 50 percent. Accordingly, neither Entity A nor Entity B is blocked and, for purposes of the 50 Percent Rule, Blocked Person X is not considered to indirectly own any of Entity C as a result of its minority ownership of Entities A or B.

While all of the OFAC examples in the FAQs address circumstances involving a single Blocked Person, the guidance would apply more broadly. For example, if Blocked Person X owns 50 percent of Entity A, and Entity A owns 25 percent of Entity B, and Blocked Person Y owns 50 percent of Entity C, which also owns 25 percent of Entity B, then the combination of the indirect ownership and 50 Percent Rule requirements may make Entity B a blocked person. While the FAQs do not address this situation, we believe OFAC would consider Entity B to be a blocked person since Entities A and C would each be considered blocked entities because of their 50 percent ownership by blocked persons, and in the aggregate they own 50 percent of Entity B.

Companies likely will need to undertake significant additional due diligence in order to collect the information about direct and indirect ownership interests that is necessary to make these complex calculations and to aggregate ownership information across multiple levels of a corporate structure. Indeed, OFAC urges companies considering a transaction to conduct “appropriate due diligence” on the involved entities in order to determine relevant ownership stakes.

Under certain limited circumstances, it may be possible for one or more blocked persons to divest their ownership stake in an entity in order to ensure that the combined ownership by blocked persons in the entity is less than 50 percent. However, these actions must be undertaken entirely outside of U.S. jurisdiction and without the involvement of any U.S. persons. Companies also should be careful to avoid “sham transactions” by conducting sufficient due diligence to be confident that any purported divestment actually occurred before they enter into any dealings with entities that were previously owned 50 percent or more by one or more designated parties.

If the aggregate ownership of blocked parties in an entity falls below 50 percent due to the actions of one or more of the blocked parties, including the entity itself, any property or interests in property that were previously in the United States or the possession or control of a U.S. person remain blocked and cannot be dealt in absent licensing or other authorization from OFAC. This is because OFAC does not recognize the unlicensed transfer of blocked property in the United States or in the possession or control of a U.S. person. This position imposes an additional layer of due diligence as it suggests that U.S. persons may need to conduct a retrospective analysis of the property of entities that they learn are minority owned by a blocked party in order to ensure that the entity was not previously owned 50 percent or more in the aggregate by blocked parties.”

————————————————————–

Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition Defense, OFAC SDN Sanctions Removal, International Criminal Court Defense, and US Seizure of Non-Resident, Foreign-Owned Assets. Because we have experience dealing with INTERPOL, our firm understands the inter-relationship that INTERPOL’s “Red Notice” brings to this equation.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.

————————————————————–

International criminal defense questions, but want to be anonymous?

Free Skype Tel: +1.202.470.3427, OR

Free Skype call:

           Office Locations

Email:


“Hotel owned by blacklisted businessman was only option, embassy says”

August 14, 2014

The Myanmar Times on August 14, 2014 released the following:

“By Tim McLaughlin

The United States Embassy in Yangon said that it failed to recognise early enough that a hotel it was assigned by the Ministry of Foreign Affairs was owned and constructed by a blacklisted businessman, leaving no option but to use the venue to host Secretary of State John Kerry last weekend.

The Myanmar Times reported on August 10 that Mr Kerry stayed at the Lake Garden Hotel Nay Pyi Taw owned by sanctioned tycoon U Zaw Zaw and constructed by U Zaw Zaw’s company Max Myanmar, which also appears on the US sanctions list.

The spokesperson said that the US delegation was assigned the hotel by the Ministry of Foreign Affairs and asked for the hotel to be changed when they became aware of the issue, but other accommodation could not be arranged.

“We recognised late the owner of the hotel assigned to us was on the list, but less problematic alternative hotels that also met our safety and security standards were not available,” the spokesperson told The Myanmar Times on August 13.

Mr Kerry, who was in Myanmar to for a round of ASEAN meetings, did not violate any US sanctions with his stay. The International Emergency Economic Powers Act, which details regulations for dealing with SDN Listed individuals and entities includes, “an exemption for activities related to travel, including hotel accommodations. This applies to the U.S. delegation’s use of the Lake Garden Hotel,” the spokesperson said.

During his visit, Mr Kerry touted the significance of what remains of his country’s sanctions regime against Myanmar on August 10, describing it as a sign that Washington is keen to avoid rushing its engagement with Nay Pyi Taw.

“Sanctions now are very much focused on members of the junta and on key individuals who may still be representing a challenge to achieving some of these [Myanmar's] goals,” he told members of the media while speaking at the Lake Garden.

Marie Harf, deputy spokesperson at the State Department, was insistent that hotel stay did not send mixed messages about US sanctions against Myanmar when questioned by reporters in Washington.

The US has eased most of its sanctions against Myanmar in response to reforms undertaken by President U Thein Sein, but still maintains targeted sanctions against some individuals and companies as piece of its “calibrated” reengagement that has hinged in part on a commitment to responsible investment in Myanmar.

Most companies and persons that appear on the SDN list are alleged to have profited from close relationships with the previous military junta. Entities and individuals that are SDN listed are barred from engaging in business with US companies and their assets are frozen in the US. A number of Myanmar’s largest and best-known firms are on the list.

US Assistant Secretary of State for Democracy, Human Rights and Labor Tom Malinowski, met with individuals who are on the SDN list during his visit to Myanmar in June. He said that many appeared “very eager” to take steps to have themselves and their companies removed from the list.

Mr Malinowski, who did not reveal which SDN-listed individuals he met during his trip, said the legal process for getting removed from the list includes demonstrating responsible business practices and showing that an individual or entity has cut ties with the military

The Lake Garden property where Mr Kerry and his delegation stayed is managed by French hotel chain Accor under its MGallery brand. Both U Zaw Zaw and his Max Myanmg group of companies were added to the Special Designated Nationals (SDN) list in 2009, according to the Treasury Department’s website.

Max Myanmar and Accor signed a contract to develop three properties in Myanmar, including the Lake Garden, in 2013. Two other properties connected to U Zaw Zaw – the Max Hotel at Chaungtha Beach and the Royal Kumudra Hotel in Nay Pyi Taw – are on the SDN list.

According to the Lake Garden website, the luxury property has 165 rooms and suites and boasts a cigar lounge and wine cellar. Rooms were advertised as starting at US$115 a night. It was unclear how many rooms the American delegation was occupying. Other US officials in Nay Pyi Taw for the regional meeting stayed at a separate hotel.”

————————————————————–

Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition Defense, OFAC SDN Sanctions Removal, International Criminal Court Defense, and US Seizure of Non-Resident, Foreign-Owned Assets. Because we have experience dealing with INTERPOL, our firm understands the inter-relationship that INTERPOL’s “Red Notice” brings to this equation.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.

————————————————————–

International criminal defense questions, but want to be anonymous?

Free Skype Tel: +1.202.470.3427, OR

Free Skype call:

           Office Locations

Email:


OFAC: “Treasury Sanctions Members of a Chinese Synthetic Drug Trafficking Organization”

July 29, 2014

The U.S. Treasury Department’s Office of Foreign Assets Control on July 29, 2014 released the following:

Sanctions Target Manufacturer, Owner, and Associates Responsible for Shipping Thousands of Kilograms of Synthetic Drugs and Controlled Substances Worldwide

WASHINGTON – The U.S. Department of the Treasury today designated members of a synthetic drug trafficking organization led by Chinese national Zhang Lei (a.k.a. Eric Chang) under the Foreign Narcotics Kingpin Designation Act (Kingpin Act). Through his company, CEC Limited, Zhang manufactures and sells substances over the internet to consumers internationally, including bath salts (mephedrone), other synthetic psychoactive substances, and chemicals that can be combined with other substances to create synthetic psychoactive substances (precursors). In addition to designating Zhang, the Treasury Department also designated today CEC Limited and three other individuals who work for the company and Zhang. As a result of today’s action, all assets of those designated today that are based in the United States or are in control of U.S. persons are frozen, and U.S. persons are generally prohibited from engaging in transactions with them.

“Global synthetic drug suppliers like Zhang Lei have fueled an epidemic of hospitalizations, paralysis, and deaths, especially among young adults,” said Adam J. Szubin, Director of the Office of Foreign Assets Control. “We intend to disrupt these networks’ operations and deny them the ability to conduct international trade.”

For over a decade, Zhang has shipped thousands of kilograms of synthetic drugs and controlled substances, including mephedrone, into the United States and other countries – including Australia, Austria, France, Germany, the Netherlands, and Italy. According to its website, Zhang’s company, CEC Limited, is a manufacturer of various chemical compounds. The company has been the source of supply for synthetic drugs sent throughout the United States and Europe. Shipments to the United States earned Zhang roughly $30 million. As the United States and other countries banned new psychoactive substances, Zhang and his associates developed replacement chemicals or used fraudulent shipping labels to continue to traffic illicit narcotics. Chinese authorities arrested Zhang on November 7, 2013 under charges of teaching criminal methods to others.

Other individuals designated today include Chinese nationals Wang Guoying, Zhang Jicheng, and Hu Yongan. Wang Guoyang is Zhang Lei’s mother and part owner of CEC Limited. She received of hundreds of thousands of dollars in payments for illicit synthetic substances. The other two individuals, Zhang Jicheng and Hu Yongan, are employees of CEC Limited and had previously been incarcerated in the United Kingdom for their role in establishing a clandestine laboratory in the United Kingdom for the industrial-scale production of synthetic drugs.

Today’s action is the result of a joint investigation by OFAC and the Drug Enforcement Administration (DEA). These designations complement law enforcement actions through the DEA’s Project Synergy, an ongoing investigation of worldwide synthetic drug manufacturers and distributors.

Since June 2000 more than 1,600 individuals and entities have been named pursuant to the Kingpin Act for their role in international narcotics trafficking. Penalties for violations of the Kingpin Act range from civil penalties of up to $1.075 million per violation to more severe criminal penalties. Criminal penalties for corporate officers may include up to 30 years in prison and fines up to $5 million. Criminal fines for corporations may reach $10 million. Other individuals face up to 10 years in prison and fines pursuant to Title 18 of the United States Code for criminal violations of the Kingpin Act.

To view a chart of the Zhang Lei and CEC Limited network, click here.

For a complete listing of designations pursuant to the Kingpin Act, click here.

For information from the DEA about synthetic psychoactive substances, click here.”

————————————————————–

Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition Defense, OFAC SDN Sanctions Removal, International Criminal Court Defense, and US Seizure of Non-Resident, Foreign-Owned Assets. Because we have experience dealing with INTERPOL, our firm understands the inter-relationship that INTERPOL’s “Red Notice” brings to this equation.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.

————————————————————–

International criminal defense questions, but want to be anonymous?

Free Skype Tel: +1.202.470.3427, OR

Free Skype call:

           Office Locations

Email:


“Treasury Designates Seven Individuals And One Entity Contributing To The Situation In Ukraine”

April 14, 2014

The U.S. Treasury Department’s Office of Foreign Assets Control on April 11, 2014 released the following:

Sanctions Target Crimean Separatists, a former Ukrainian Official,
and a Crimea-based Gas Company

WASHINGTON – The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today designated Crimean separatist leaders Pyotr Zima, Aleksei Chaliy, Rustam Temirgaliev, Yuriy Zherebtsov, Mikhail Malyshev, and Valery Medvedev, former Ukrainian official Sergey Tsekov, and Crimea-based gas company Chernomorneftegaz pursuant to Executive Order (E.O.) 13660. These individuals and this entity are being sanctioned for being responsible for or complicit in, or having engaged in, actions or policies that undermine democratic processes or institutions in Ukraine, actions or policies that threaten the peace, security, stability, sovereignty, or territorial integrity of Ukraine, or misappropriation of state assets of Ukraine or of an economically significant entity in Ukraine; or having asserted governmental authority over any part or region of Ukraine without the authorization of the Government of Ukraine.

“Crimea is occupied territory. We will continue to impose costs on those involved in ongoing violations of Ukraine’s sovereignty and territorial integrity,” said Under Secretary for Terrorism and Financial Intelligence David S. Cohen.

Crimean Separatists

Pyotr Zima was appointed as de facto head of the Security Service of Ukraine’s main directorate in Crimea by the presidium of the Crimean parliament in March 2014. Zima was subsequently dismissed from his duties by interim Ukrainian President Oleksandr Turchynov for taking an oath of loyalty to the new Crimean authorities, and the Prosecutor-General’s Office of Ukraine received permission from a Ukrainian district court to detain Zima for colluding with Sergei Aksenov and Vladimir Konstantinov to commit crimes under Article 109 Part 1 of the Ukrainian Criminal Code. Aksenov and Konstantinov were designated on March 17, 2014 pursuant to E.O. 13660. Zima is being designated pursuant to E.O. 13660 because he has asserted governmental authority over a part or region of Ukraine without the authorization of the Government of Ukraine.

Aleksei Chaliy is the de facto Chairman of the Coordinating Council for the establishment of the Sevastopol municipal administration, and signed the March 16, 2014 agreement between the Russian Federation and the “Republic of Crimea” to unite Crimea and the city of Sevastopol with Russia. Chaliy is being designated pursuant to E.O. 13660 because he has asserted governmental authority over any part or region of Ukraine without the authorization of the Government of Ukraine; and because he is responsible for or complicit in, or has engaged in, directly or indirectly, actions or policies that threaten the peace, security, stability, sovereignty, or territorial integrity of Ukraine.

As de facto Deputy Chairman of the Council of Ministers of Crimea, Rustam Temirgaliev ran the unauthorized March 16, 2014 referendum in Crimea.

As de facto counselor to the Speaker of the Crimean parliament, the Rada, Yuriy Zherebtsov was one of the main organizers of the unauthorized March 16 referendum in Crimea, which paved the way for Russia’s illegal annexation of Crimea. On March 9, 2014, Zherebtsov signed a letter on behalf of the authorities of “the Autonomous Republic of Crimea” requesting the commander of the military base in Yevpatoria, Crimea to disarm his troops and surrender the base to the Black Sea Fleet of the Russian Federation.

Mikhail Malyshev is the de facto Chair of the Crimea Electoral Commission, which administered the unauthorized March 16, 2014 referendum in Crimea.

Valery Medvedev is the de facto Chair of the Sevastopol Electoral Commission, which administered the unauthorized March 16, 2014 referendum for the city of Sevastopol.

Temirgaliev, Zherebtsov, Malyshev, and Medvedev are being designated pursuant to E.O. 13660 because they are responsible for or complicit in, or have engaged in, directly or indirectly, actions or policies that threaten the peace, security, stability, sovereignty, or territorial integrity of Ukraine. Zherebtsov is also being designated because he is responsible for or complicit in, or has engaged in, directly or indirectly, actions or policies that undermine democratic processes or institutions in Ukraine.

Former Ukrainian Official

Sergey Tsekov was the Vice Speaker of Ukraine’s parliament, the Verkhovna Rada, and was responsible for facilitating the unauthorized referendum that paved the way for Russia’s illegal annexation of Crimea. Tsekov is being designated pursuant to E.O. 13660 because he is responsible for or complicit in, or has engaged in, directly or indirectly, actions or policies that threaten the peace, security, stability, sovereignty, or territorial integrity of Ukraine.

Crimean Entity

On March 18, 2014 the Crimean parliament passed a resolution to seize the Crimean assets of a subsidiary of a Ukrainian state-owned gas company which has drilling rigs off Crimea’s west coast and in the Sea of Azov. The assets were transferred to an entity with the same name, Chernomorneftegaz, and same address. The parliament’s resolution said the takeover would include ownership of the region’s “continental shelf and the exclusive (maritime) economic zone.” Chernomorneftegaz is being designated pursuant to E.O. 13660 because it is complicit in the misappropriation of state assets of Ukraine or of an economically significant entity in Ukraine.

As a result of Treasury’s action, any assets of the persons designated today that are within U.S. jurisdiction must be frozen. Additionally, transactions by U.S. persons or with the United States involving these individuals and entity are generally prohibited.

Identifying Information

Name: Pyotr Anatoliyovych Zima
AKA: Petr Anatolyevich Zima
AKA: Petro Zyma
DOB: 29 March 1965
POB: Russia
Address: 18 Ulitsa D. Ulyanova, Apartment 110, Simferopol, Crimea, Ukraine
Title: Head of the Crimean SBU (Security Service of Ukraine)

Name: Aleksei Mikhailovich Chaliy
AKA.: Aleksey Mikhailovich Chaliy
AKA.: Aleksey Mykhaylovych Chaliy
AKA.: Oleksiy Mikhailovich Chaliy
AKA.: Aleksey Mikhailovich Chaly
AKA.: Aleksei Mikhailovich Chaliy
AKA.: Alexei Chaly
AKA.: Aleksei Chaliy
AKA.: Alexei Chaliy
DOB: 13 June 1961
POB: Sevastopol, Ukraine
Title: Mayor of Sevastopol
Title: Chairman of the Coordination Council for the Establishment of the
Sevastopol Municipal Administration

Name: Rustam Ilmirovich Temirgaliev
DOB: 15 August 1976
POB: Ulan-Ude, Russian Federation
Title: Deputy Chairman of the Council of Ministers of Crimea
Title: Crimean Deputy Prime Minister

Name: Yuriy Gennadyevich Zherebtsov
AKA: Yury Zherebtsov
DOB: 19 November 1969
POB: Odessa, Ukraine
Title: Counselor to the Speaker of the Crimean Rada

Name: Mikhail Grigorevich Malyshev
DOB: 10 October 1955
POB: Simferopol, Crimea, Ukraine
Address: 15/9 Ulitsa Turgeneva, Apt. 9, Simferopol, Crimea, Ukraine
Title: Chair of the Crimea Electoral Commission

Name: Valery Kirillovich Medvedev
DOB: 21 August 1946
POB: Russia
Address: 22 Ulitsa Oktyabrskoi Revolutsii, Building 9, Apt. 14, Sevastopol, Crimea, Ukraine
Title: Chair of the Sevastopol Electoral Commission

Name: Sergey Pavlovich Tsekov
DOB: 28 September 1953
POB: Simferopol, Crimea, Ukraine

Name: Chernomorneftegaz
AKA: Chornomornaftogaz
AKA: NJSC Chornomornaftogaz

Address: Kirova / per. Sovnarkomovskaya, 52/1, Simferopol, Crimea, 95000, Ukraine.”

————————————————————–

Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition Defense, OFAC SDN Sanctions Removal, International Criminal Court Defense, and US Seizure of Non-Resident, Foreign-Owned Assets. Because we have experience dealing with INTERPOL, our firm understands the inter-relationship that INTERPOL’s “Red Notice” brings to this equation.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.

————————————————————–

International criminal defense questions, but want to be anonymous?

Free Skype Tel: +1.202.470.3427, OR

Free Skype call:

           Office Locations

Email:


U.S. Department of the Treasury – OFAC Sanctions Alleged Sinaloa Cartel Lieutenant Jose Rodrigo Arechiga Gamboa

January 13, 2014

The Wall Street Journal on January 8, 2014 released the following:

“By SAMUEL RUBENFELD

The U.S. Treasury Department’s Office of Foreign Assets Control placed Kingpin Act sanctions on a senior lieutenant of the Sinaloa Cartel.

Jose Rodrigo Arechiga Gamboa, who is also known as Chino Antrax, controls Los Antrax, which provides security and protection for Ismael “Mayo” Zambada Garcia and his family, and is responsible for eliminating Mr. Zambada Garcia’s rivals, Treasury said.

Mr. Arechiga Gamboa also handles transport and logistics for Joaquin Guzman Loera, who leads the Sinaloa Cartel, Treasury said. In addition, he worked with a Sinaloa cartel lieutenant killed by Mexican authorities in December, Treasury said.

Mr. Arechiga Gamboa “represents the next generation of hyper violent drug traffickers,” said Adam Szubin, director of OFAC, in a statement.

Treasury said Mr. Arechiga Gamboa was charged Dec. 20 in a sealed indictment by a grand jury in the Southern District of California with two counts of narcotics trafficking violations. He was arrested 10 days later by Dutch authorities at an Amsterdam airport, and the indictment was unsealed Jan. 3, Treasury said. The U.S. is seeking his extradition.”

————————————————————–

Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition Defense, OFAC SDN Sanctions Removal, International Criminal Court Defense, and US Seizure of Non-Resident, Foreign-Owned Assets. Because we have experience dealing with INTERPOL, our firm understands the inter-relationship that INTERPOL’s “Red Notice” brings to this equation.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.

————————————————————–

International criminal defense questions, but want to be anonymous?

Free Skype Tel: +1.202.470.3427, OR

Free Skype call:

           Office Locations

Email:


U.S. Department of the Treasury: “Kingpin Act Designations”

October 1, 2013

The U.S. Department of the Treasury on September 30, 2013 released the following:

“OFFICE OF FOREIGN ASSETS CONTROL
Specially Designated Nationals List Update:

The following individuals have been added to OFAC’s SDN List:

PADRO PASTOR, Alvaro; DOB 09 Nov 1975; nationality Spain; R.F.C. PAPA751109870 (Mexico); C.U.R.P. PAPA751109HNEDSL04 (Mexico) (individual) [SDNTK] (Linked To: CASA V; Linked To: PISCILANEA, S.A. DE C.V.).

VALLARTA ESCALANTE, Luis Francisco, Calle Chilam Balam No. 279, Supermanzana 50, Manzana 14, Lote 17, Residencial San Angel, Cancun, Quintana Roo, Mexico; DOB 24 Nov 1979; POB Torreon, Coahuila de Zaragoza, Mexico; R.F.C. VAEL791124NXA (Mexico); C.U.R.P. VAEL791124HCLLSS07 (Mexico) (individual) [SDNTK] (Linked To: GRUPO IMPERGOZA, S.A. DE C.V.; Linked To: SOCIALIKA RENTAS Y CATERING, S.A. DE C.V.).

The following entity has been added to OFAC’s SDN List:

CASA V, Av. Vallarta 1339, Colonia Americana, Guadalajara, Jalisco, Mexico [SDNTK].”

————————————————————–

Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition Defense, OFAC SDN Sanctions Removal, International Criminal Court Defense, and US Seizure of Non-Resident, Foreign-Owned Assets. Because we have experience dealing with INTERPOL, our firm understands the inter-relationship that INTERPOL’s “Red Notice” brings to this equation.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.

————————————————————–

International criminal defense questions, but want to be anonymous?

Free Skype Tel: +1.202.470.3427, OR

Free Skype call:

           Office Locations

Email:


U.S. Department of the Treasury: “Anti-terrorism Designations​​ Removals; Kingpin Act Designations​ Removals; Counter Narcotics Designations Removals”

October 1, 2013

The U.S. Department of the Treasury on September 26, 2013 released the following:

“OFFICE OF FOREIGN ASSETS CONTROL

Specially Designated Nationals List Update

The following deletions have been made to OFAC’s SDN List:

AL-QUSO, Fahd Mohammed Ahmed (a.k.a. AL-AWLAQI, Fahd Mohammed Ahmed; a.k.a. AL-KUSSO, Fahd Muhammad Ahmed; a.k.a. AL-QUSO, Fahd; a.k.a. “ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH”; a.k.a. “ABU HUTHAIFAH AL-ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH AL-ADANI”; a.k.a. “ABU HUTHAIFAH AL-YEMENI”; a.k.a. “ABU HUTHAYFAH AL-ADANI”; a.k.a. “HUTHAIFAH AL-YEMENI”); DOB 12 Nov 1974; POB Aden, Yemen; citizen Yemen; Height 5 feet, 6 inches; Eye Color Black; Complexion Olive; Hair Color Black; Weight 150 pounds; National ID No. 2043 (individual) [SDGT].

AL-QUSO, Fahd (a.k.a. AL-AWLAQI, Fahd Mohammed Ahmed; a.k.a. AL-KUSSO, Fahd Muhammad Ahmed; a.k.a. AL-QUSO, Fahd Mohammed Ahmed; a.k.a. “ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH”; a.k.a. “ABU HUTHAIFAH AL-ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH AL-ADANI”; a.k.a. “ABU HUTHAIFAH AL-YEMENI”; a.k.a. “ABU HUTHAYFAH AL-ADANI”; a.k.a. “HUTHAIFAH AL-YEMENI”); DOB 12 Nov 1974; POB Aden, Yemen; citizen Yemen; Height 5 feet, 6 inches; Eye Color Black; Complexion Olive; Hair Color Black; Weight 150 pounds; National ID No. 2043 (individual) [SDGT].

“ABU HUTHAIFAH” (a.k.a. AL-AWLAQI, Fahd Mohammed Ahmed; a.k.a. AL-KUSSO, Fahd Muhammad Ahmed; a.k.a. AL-QUSO, Fahd; a.k.a. AL-QUSO, Fahd Mohammed Ahmed; a.k.a. “ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH AL-ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH AL-ADANI”; a.k.a. “ABU HUTHAIFAH AL-YEMENI”; a.k.a. “ABU HUTHAYFAH AL-ADANI”; a.k.a. “HUTHAIFAH AL-YEMENI”); DOB 12 Nov 1974; POB Aden, Yemen; citizen Yemen; Height 5 feet, 6 inches; Eye Color Black; Complexion Olive; Hair Color Black; Weight 150 pounds; National ID No. 2043 (individual) [SDGT].

“ABU HUTHAIFAH AL-YEMENI” (a.k.a. AL-AWLAQI, Fahd Mohammed Ahmed; a.k.a. AL-KUSSO, Fahd Muhammad Ahmed; a.k.a. AL-QUSO, Fahd; a.k.a. AL-QUSO, Fahd Mohammed Ahmed; a.k.a. “ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH”; a.k.a. “ABU HUTHAIFAH AL-ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH AL-ADANI”; a.k.a. “ABU HUTHAYFAH AL-ADANI”; a.k.a. “HUTHAIFAH AL-YEMENI”); DOB 12 Nov 1974; POB Aden, Yemen; citizen Yemen; Height 5 feet, 6 inches; Eye Color Black; Complexion Olive; Hair Color Black; Weight 150 pounds; National ID No. 2043 (individual) [SDGT].

“ABU HUTHAIFAH AL-ADANI” (a.k.a. AL-AWLAQI, Fahd Mohammed Ahmed; a.k.a. AL-KUSSO, Fahd Muhammad Ahmed; a.k.a. AL-QUSO, Fahd; a.k.a. AL-QUSO, Fahd Mohammed Ahmed; a.k.a. “ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH”; a.k.a. “ABU HUTHAIFAH AL-ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH AL-YEMENI”; a.k.a. “ABU HUTHAYFAH AL-ADANI”; a.k.a. “HUTHAIFAH AL-YEMENI”); DOB 12 Nov 1974; POB Aden, Yemen; citizen Yemen; Height 5 feet, 6 inches; Eye Color Black; Complexion Olive; Hair Color Black; Weight 150 pounds; National ID No. 2043 (individual) [SDGT].

“ABU AL-BARA” (a.k.a. AL-AWLAQI, Fahd Mohammed Ahmed; a.k.a. AL-KUSSO, Fahd Muhammad Ahmed; a.k.a. AL-QUSO, Fahd; a.k.a. AL-QUSO, Fahd Mohammed Ahmed; a.k.a. “ABU HUTHAIFAH”; a.k.a. “ABU HUTHAIFAH AL-ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH AL-ADANI”; a.k.a. “ABU HUTHAIFAH AL-YEMENI”; a.k.a. “ABU HUTHAYFAH AL-ADANI”; a.k.a. “HUTHAIFAH AL-YEMENI”); DOB 12 Nov 1974; POB Aden, Yemen; citizen Yemen; Height 5 feet, 6 inches; Eye Color Black; Complexion Olive; Hair Color Black; Weight 150 pounds; National ID No. 2043 (individual) [SDGT].

“ABU HUTHAYFAH AL-ADANI” (a.k.a. AL-AWLAQI, Fahd Mohammed Ahmed; a.k.a. AL-KUSSO, Fahd Muhammad Ahmed; a.k.a. AL-QUSO, Fahd; a.k.a. AL-QUSO, Fahd Mohammed Ahmed; a.k.a. “ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH”; a.k.a. “ABU HUTHAIFAH AL-ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH AL-ADANI”; a.k.a. “ABU HUTHAIFAH AL-YEMENI”; a.k.a. “HUTHAIFAH AL-YEMENI”); DOB 12 Nov 1974; POB Aden, Yemen; citizen Yemen; Height 5 feet, 6 inches; Eye Color Black; Complexion Olive; Hair Color Black; Weight 150 pounds; National ID No. 2043 (individual) [SDGT].

AL-AWLAQI, Fahd Mohammed Ahmed (a.k.a. AL-KUSSO, Fahd Muhammad Ahmed; a.k.a. AL-QUSO, Fahd; a.k.a. AL-QUSO, Fahd Mohammed Ahmed; a.k.a. “ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH”; a.k.a. “ABU HUTHAIFAH AL-ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH AL-ADANI”; a.k.a. “ABU HUTHAIFAH AL-YEMENI”; a.k.a. “ABU HUTHAYFAH AL-ADANI”; a.k.a. “HUTHAIFAH AL-YEMENI”); DOB 12 Nov 1974; POB Aden, Yemen; citizen Yemen; Height 5 feet, 6 inches; Eye Color Black; Complexion Olive; Hair Color Black; Weight 150 pounds; National ID No. 2043 (individual) [SDGT].

“HUTHAIFAH AL-YEMENI” (a.k.a. AL-AWLAQI, Fahd Mohammed Ahmed; a.k.a. AL-KUSSO, Fahd Muhammad Ahmed; a.k.a. AL-QUSO, Fahd; a.k.a. AL-QUSO, Fahd Mohammed Ahmed; a.k.a. “ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH”; a.k.a. “ABU HUTHAIFAH AL-ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH AL-ADANI”; a.k.a. “ABU HUTHAIFAH AL-YEMENI”; a.k.a. “ABU HUTHAYFAH AL-ADANI”); DOB 12 Nov 1974; POB Aden, Yemen; citizen Yemen; Height 5 feet, 6 inches; Eye Color Black; Complexion Olive; Hair Color Black; Weight 150 pounds; National ID No. 2043 (individual) [SDGT].

“ABU HUTHAIFAH AL-ABU AL-BARA” (a.k.a. AL-AWLAQI, Fahd Mohammed Ahmed; a.k.a. AL-KUSSO, Fahd Muhammad Ahmed; a.k.a. AL-QUSO, Fahd; a.k.a. AL-QUSO, Fahd Mohammed Ahmed; a.k.a. “ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH”; a.k.a. “ABU HUTHAIFAH AL-ADANI”; a.k.a. “ABU HUTHAIFAH AL-YEMENI”; a.k.a. “ABU HUTHAYFAH AL-ADANI”; a.k.a. “HUTHAIFAH AL-YEMENI”); DOB 12 Nov 1974; POB Aden, Yemen; citizen Yemen; Height 5 feet, 6 inches; Eye Color Black; Complexion Olive; Hair Color Black; Weight 150 pounds; National ID No. 2043 (individual) [SDGT].

AL-KUSSO, Fahd Muhammad Ahmed (a.k.a. AL-AWLAQI, Fahd Mohammed Ahmed; a.k.a. AL-QUSO, Fahd; a.k.a. AL-QUSO, Fahd Mohammed Ahmed; a.k.a. “ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH”; a.k.a. “ABU HUTHAIFAH AL-ABU AL-BARA”; a.k.a. “ABU HUTHAIFAH AL-ADANI”; a.k.a. “ABU HUTHAIFAH AL-YEMENI”; a.k.a. “ABU HUTHAYFAH AL-ADANI”; a.k.a. “HUTHAIFAH AL-YEMENI”); DOB 12 Nov 1974; POB Aden, Yemen; citizen Yemen; Height 5 feet, 6 inches; Eye Color Black; Complexion Olive; Hair Color Black; Weight 150 pounds; National ID No. 2043 (individual) [SDGT].

HAQQANI, Badruddin (a.k.a. “ATIQULLAH”), Miram Shah, Pakistan; DOB 1975; alt. DOB 1976; alt. DOB 1977; alt. DOB 1978; alt. DOB 1979; Individual’s Primary Language Pashto; Eye Color Brown; Hair Color Brown; Operational Commander of the Haqqani Network (individual) [SDGT].

“ATIQULLAH” (a.k.a. HAQQANI, Badruddin), Miram Shah, Pakistan; DOB 1975; alt. DOB 1976; alt. DOB 1977; alt. DOB 1978; alt. DOB 1979; Individual’s Primary Language Pashto; Eye Color Brown; Hair Color Brown; Operational Commander of the Haqqani Network (individual) [SDGT].

DESME HURTADO, Maximo Zadi (a.k.a. DESME, Zadi), c/o AVIANDINA S.A.C., Lima, Peru; c/o SISTEMA DE DISTRIBUCION MUNDIAL S.A.C., Lima, Peru; Cerro Alto De La Posada 58, Los Andes, Chile; DOB 21 Aug 1958; LE Number 06367724 (Peru) (individual) [SDNTK].

DESME, Zadi (a.k.a. DESME HURTADO, Maximo Zadi), c/o AVIANDINA S.A.C., Lima, Peru; c/o SISTEMA DE DISTRIBUCION MUNDIAL S.A.C., Lima, Peru; Cerro Alto De La Posada 58, Los Andes, Chile; DOB 21 Aug 1958; LE Number 06367724 (Peru) (individual) [SDNTK].

SERRALDE RODRIGUEZ, Carlos Hernan, c/o AGROPECUARIA SERRO S.A.S., Bogota, Colombia; c/o ASOCIACION COLOMBIANA DE CRIADORES DE GANADO LIMOUSIN, Bogota, Colombia; Calle 152 No. 58-51 Apto. 501 – Torre 5, Bogota, Colombia; DOB 08 Oct 1975; POB Bogota, Colombia; Cedula No. 79689496 (Colombia) (individual) [SDNTK].

RODRIGUEZ ROMERO, Martha Ines, c/o AGROPECUARIA SERRO S.A.S., Bogota, Colombia; c/o FERTILIZANTES LIQUIDOS DE LA SABANA LTDA., Bogota, Colombia; Calle 109 No. 21-41 Apto. 403, Bogota, Colombia; Calle 109 No. 21-01 Apto. 401, Bogota, Colombia; DOB 18 May 1953; POB Bogota, Colombia; Cedula No. 41590271 (Colombia) (individual) [SDNTK].

FERTILIZANTES LIQUIDOS DE LA SABANA LTDA. (a.k.a. FERTILISA LTDA.), Calle 98 Bis No. 57-66, Bogota, Colombia; Calle 98 Bis No. 71A-66, Bogota, Colombia; Via Siberia-Cota Km. 6, Vereda Rozo, Finca Ancon, Cota, Cundinamarca, Colombia; NIT # 860536101-7 (Colombia) [SDNTK].

FERTILISA LTDA. (a.k.a. FERTILIZANTES LIQUIDOS DE LA SABANA LTDA.), Calle 98 Bis No. 57-66, Bogota, Colombia; Calle 98 Bis No. 71A-66, Bogota, Colombia; Via Siberia-Cota Km. 6, Vereda Rozo, Finca Ancon, Cota, Cundinamarca, Colombia; NIT # 860536101-7 (Colombia) [SDNTK].

ASOCIACION COLOMBIANA DE CRIADORES DE GANADO LIMOUSIN (a.k.a. ASOLIMOUSIN), Carrera 14A No. 101-11 Of. 403, Bogota, Colombia; NIT # 800099351-8 (Colombia) [SDNTK].

ASOLIMOUSIN (a.k.a. ASOCIACION COLOMBIANA DE CRIADORES DE GANADO LIMOUSIN), Carrera 14A No. 101-11 Of. 403, Bogota, Colombia; NIT # 800099351-8 (Colombia) [SDNTK].

AGROPECUARIA SERRO S.A.S. (a.k.a. AGROSERRO), Carrera 14A No. 101-11 Of. 403, Bogota, Colombia; Finca Criadero Las Palmas, Guaymaral, Cundinamarca, Colombia; NIT # 890935433-8 (Colombia) [SDNTK].

AGROSERRO (a.k.a. AGROPECUARIA SERRO S.A.S.), Carrera 14A No. 101-11 Of. 403, Bogota, Colombia; Finca Criadero Las Palmas, Guaymaral, Cundinamarca, Colombia; NIT # 890935433-8 (Colombia) [SDNTK].

RODRIGUEZ OREJUELA DE GIL, Amparo; DOB 13 Mar 1949; Cedula No. 31218703 (Colombia); Passport AC342062 (Colombia) (individual) [SDNT] (Linked To: LABORATORIOS BLAIMAR DE COLOMBIA S.A.; Linked To: DISTRIBUIDORA MIGIL LTDA.; Linked To: DEPOSITO POPULAR DE DROGAS S.A.; Linked To: LABORATORIOS KRESSFOR DE COLOMBIA S.A.; Linked To: LABORATORIOS BLANCO PHARMA S.A.; Linked To: RADIO UNIDAS FM S.A.; Linked To: DISTRIBUIDORA DE DROGAS CONDOR LTDA.; Linked To: D’CACHE S.A.; Linked To: LABORATORIOS Y COMERCIALIZADORA DE MEDICAMENTOS DROBLAM S.A.; Linked To: AQUILEA S.A.).

CEDENO HERRERA, Luis Mario, c/o COMPANIA AGROPECUARIA DEL SUR LTDA., Bogota, Colombia; c/o INVERSIONES AGROINDUSTRIALES DEL OCCIDENTE LTDA., Bogota, Colombia; c/o AGROPECUARIA LINDARAJA S.A., Cali, Colombia; c/o INVERSIONES BRASILAR S.A., Bogota, Colombia; nationality Colombia; citizen Colombia; Cedula No. 16637213 (Colombia) (individual) [SDNT].

GRAJALES MEJIA, Jose Agustin, c/o AGUSTIN GRAJALES Y CIA. LTDA., La Union, Valle, Colombia; DOB 29 Dec 1952; POB La Union, Valle, Colombia; Cedula No. 14990496 (Colombia) (individual) [SDNT].

SABAGH DE CURE, Maria Dunia, c/o CURE SABAGH Y CIA. S.C.S., Barranquilla, Colombia; c/o FUDIA LTDA., Barranquilla, Colombia; DOB 02 Jan 1947; POB Barranquilla, Colombia; Cedula No. 33278803 (Colombia); Passport AE330188 (Colombia) (individual) [SDNT].

GONZALEZ SANCLEMENTE, Fernando, Colombia; DOB 16 Jul 1963; Cedula No. 14884862 (Colombia) (individual) [SDNT].

GONZALEZ SANCLEMENTE, Jose Alberto, c/o AGROINDUSTRIAS JORDANES S.A., Cali, Colombia; c/o FEGO CANA E.U., Cali, Colombia; c/o IMERCO LTDA., San Pedro, Valle, Colombia; DOB 10 Sep 1971; alt. DOB 09 Oct 1971; POB Buga, Valle, Colombia; Cedula No. 14894820 (Colombia) (individual) [SDNT].

GONZALEZ SANCLEMENTE, Alejandro, c/o IMERCO LTDA., San Pedro, Valle, Colombia; DOB 26 Feb 1960; POB Buga, Valle, Colombia; Cedula No. 14882775 (Colombia) (individual) [SDNT].

IMERCO LTDA., Calle Ruta Buga – Tulua 4 Kilometros despues de San Pedro, San Pedro, Valle, Colombia; NIT # 810004154-2 (Colombia) [SDNT].

FEGO CANA E.U., Calle 11A No. 116-40 Casa 3, Cali, Colombia; NIT # 830500953-0 (Colombia); Matricula Mercantil No 680975-15 (Colombia) [SDNT].

AGROINDUSTRIAS JORDANES S.A. (a.k.a. JORDANES PARRILLA ARGENTINA), Calle 8 No. 25-46, Cali, Colombia; Calle 9A Norte No. 4N-23, Oficina 101E, Cali, Colombia; Calle 18N No. 9-07, Cali, Colombia; Carrera 98 No. 16-200, Local R6, Cali, Colombia; Carrera 105 Calle 15D, Loc. 5 y 6, Cali, Colombia; NIT # 900092924-9 (Colombia) [SDNT].

JORDANES PARRILLA ARGENTINA (a.k.a. AGROINDUSTRIAS JORDANES S.A.), Calle 8 No. 25-46, Cali, Colombia; Calle 9A Norte No. 4N-23, Oficina 101E, Cali, Colombia; Calle 18N No. 9-07, Cali, Colombia; Carrera 98 No. 16-200, Local R6, Cali, Colombia; Carrera 105 Calle 15D, Loc. 5 y 6, Cali, Colombia; NIT # 900092924-9 (Colombia) [SDNT].”

————————————————————–

Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition Defense, OFAC SDN Sanctions Removal, International Criminal Court Defense, and US Seizure of Non-Resident, Foreign-Owned Assets. Because we have experience dealing with INTERPOL, our firm understands the inter-relationship that INTERPOL’s “Red Notice” brings to this equation.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.

————————————————————–

International criminal defense questions, but want to be anonymous?

Free Skype Tel: +1.202.470.3427, OR

Free Skype call:

           Office Locations

Email:


Follow

Get every new post delivered to your Inbox.

Join 8,469 other followers