OFAC Specially Designated Nationals (SDN) – Sanctions Law – Weapons of Mass Destruction Proliferators

April 22, 2011

Douglas McNabb discusses Weapons of Mass Destruction Proliferators (NPWMD) as one of the subject matter sanctions programs.

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OFAC SDN – Sanctions Law – Subject Matter Designation Lists

April 21, 2011

Attorney Douglas McNabb discusses the different types of OFAC SDN sanctions characterized by subject matter. Sanctions law provides for designations based on narcotics trafficking, terrorism, rough diamonds, and weapons of mass destruction proliferators.

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OFAC SDNTK DESIGNATION APRIL 20, 2011

April 20, 2011

Attorney Douglas McNabb discusses today’s designation of the leaders of Kongra-Gel as Specially Designated Narcotics Traffickers under the Kingpin Act (SDNTK).

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April 20, 2011 OFAC Actions: Specially Designated Narcotics Traffickers Kingpin (SDNTK) Added to OFAC’s SDN list

April 20, 2011

As of today, OFAC has added five (and 1 assumed name) SDNTK individuals to the Specially Designated Nationals List (SDN List):

BAYIK, Cemil; DOB 26 Feb 1955; alt. DOB 1951; alt. DOB 1954; POB Keban, Elazig, Turkey; alt. POB Hazar, Elazig, Turkey; citizen Turkey;
Turkish Identificiation Number 23860719950 (Turkey) (individual) [SDNTK]

ERDEM, Selahattin (a.k.a. KALKAN, Duran); DOB 1954; alt. DOB 1958; POB Adana, Tufanbeyli, Turkey; alt. POB Derik, Turkey; citizen Turkey;
Turkish Identificiation Number 18538165962 (Turkey) (individual) [SDNTK]

KALKAN, Duran (a.k.a. ERDEM, Selahattin); DOB 1954; alt. DOB 1958; POB Adana, Tufanbeyli, Turkey; alt. POB Derik, Turkey; citizen Turkey;
Turkish Identificiation Number 18538165962 (Turkey) (individual) [SDNTK]

KARTAL, Remzi; DOB 5 May 1948; POB Van, Dibekozu, Turkey; citizen Turkey; Turkish Identificiation Number 10298480866 (Turkey)
(individual) [SDNTK]

OK, Sabri; DOB 1958; POB Adiyaman, Turkey; citizen Turkey; Turkish Identificiation Number 15673320164 (Turkey) (individual) [SDNTK]

UZUN, Adem; DOB 7 Sep 1967; POB Kirsehir, Boztepe, Turkey; citizen Turkey; Turkish Identificiation Number 12203628318 (Turkey)
(individual) [SDNTK]

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“4/20/2011
WASHINGTON – The U.S. Department of the Treasury today announced the designation of Kongra-Gel founders Cemil Bayik and Duran Kalkan and leaders Remzi Kartal, Sabri Ok and Adem Uzun as Specially Designated Narcotics Traffickers (SDNTs) pursuant to the Foreign Narcotics Kingpin Designation Act (Kingpin Act).

Formerly known as the Kurdistan Workers’ Party (PKK), the Kongra-Gel was named by the President as a significant foreign narcotics trafficker under the Kingpin Act in May 2008 for its more than two decades-long participation in drug trafficking. Kongra-Gel uses its network across Europe to produce, transport, and traffic opiates and cannabis. Drug trafficking is one of the Kongra-Gel’s most lucrative criminal activities. The organization uses drug proceeds to obtain weapons and materials. The State Department designated the Kongra-Gel as a Specially Designated Global Terrorist in 2001 pursuant to Executive Order 13224 and as a Foreign Terrorist Organization in 1997.

“We are striking at the heart of Kongra Gel with this action against its founders, key leaders and sources of funding and will continue efforts to suppress the flow of illicit narcotics proceeds to this organization in support of its terrorist activities,” said Acting Under Secretary for Terrorism and Financial Intelligence David S. Cohen.

One of its founders, Cemil Bayik is also a senior military commander of the Kongra-Gel. Duran Kalkan serves on the group’s chairmanship council and is responsible for an attack that killed seven Turkish soldiers in December 2009. Remzi Kartal is the chief Kongra-Gel operative in Europe. Sabri Ok is a senior Kongra-Gel leader responsible for the group’s finances in Europe, and Adem Uzun operates on behalf of the Kongra-Gel in northern Iraq. Today’s action freezes any assets the five individuals may have under U.S. jurisdiction and prohibits U.S. persons from conducting financial or commercial transactions with them.

Supported by the Drug Enforcement Administration, today’s action is part of ongoing efforts pursuant to the Kingpin Act to apply financial measures against significant foreign narcotics traffickers worldwide. Internationally, more than 900 businesses and individuals linked to 87 drug kingpins have been identified for sanctions since June 2000.

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.”

See OFAC’s Press Release here.

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Douglas McNabb and other members of the firm practice and write extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN List Removal.

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

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OFAC Specially Designated Nationals List (SDN)- US Sanctions Law- Foreign Narcotics Traffickers

April 20, 2011

Attorney Douglas McNabb discusses the OFAC SDN narcotics sanctions programs including the SDNT (Columbia) and the SDNTK (Kingpin Act).

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Recent OFAC Actions: DPRK Entities Added to OFAC’s SDN list

April 19, 2011

As of today, OFAC has added to the Specially Designated Nationals List (SDN List):

BANK OF EAST LAND (a.k.a. DONGBANG BANK; a.k.a. TONGBANG BANK; a.k.a. TONGBANG U’NHAENG), PO Box 32, BEL Building, Jonseung-Dong, Moranbong District, Pyongyang, Korea, North; SWIFT/BIC BOEL KP PY (Korea, North) [DPRK]

DONGBANG BANK (a.k.a. BANK OF EAST LAND; a.k.a. TONGBANG BANK; a.k.a. TONGBANG U’NHAENG), PO Box 32, BEL Building, Jonseung-Dong, Moranbong District, Pyongyang, Korea, North; SWIFT/BIC BOEL KP PY (Korea, North) [DPRK]

TONGBANG BANK (a.k.a. BANK OF EAST LAND; a.k.a. DONGBANG BANK; a.k.a. TONGBANG U’NHAENG), PO Box 32, BEL Building, Jonseung-Dong, Moranbong District, Pyongyang, Korea, North; SWIFT/BIC BOEL KP PY (Korea, North) [DPRK]

TONGBANG U’NHAENG (a.k.a. BANK OF EAST LAND; a.k.a. DONGBANG BANK; a.k.a. TONGBANG BANK), PO Box 32, BEL Building, Jonseung-Dong, Moranbong District, Pyongyang, Korea, North; SWIFT/BIC BOEL KP PY (Korea, North) [DPRK]

“The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced the designation of North Korean financial institution Bank of East Land (aka Dongbang Bank) for its facilitation of weapons-related transactions for, and other support to, designated arms manufacturer and exporter Green Pine Associated Corporation (Green Pine).” See OFAC’s Press Release here.

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Douglas McNabb and other members of the firm practice and write extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN List Removal.

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

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OFAC-SDN-Removal Attorneys

April 18, 2011

Douglas McNabb discusses the firm’s OFAC specialization as OFAC-SDN-Removal Attorneys. The firm does not handle licensing, compliance or investigations.

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Recent OFAC Actions: LIBYA2 Designations Added to OFAC’s SDN List

April 8, 2011

On April 8, 2011, OFAC added five individuals (and 13 assumed names) and two entities (and 1 assumed name) to the LIBYA2 Specially Designated Nationals List (SDN List):

AL BAGHDADI, Ali Al-Mahmoudi (a.k.a. MAHMUDI, Baghdadi); DOB 1950; POB Al Jamil, Libya; Prime Minister (individual) [LIBYA2]

AL-TUHAMI, Khaled (a.k.a. KHALED, Al-Tohamy; a.k.a. KHALED, al-Tuhami; a.k.a. KHALED, Tohami); DOB 1946; POB Genzur, Libya; General; Director of the Internal Security Office (individual) [LIBYA2]

AL-ZULAYTINI, Abd-Al-Hafid Mahmud (a.k.a. ZLEITNI, Abdel-Hafez; a.k.a. ZLITNI, Abdelhafidh; a.k.a. ZLITNI, Abdul Hafid; a.k.a. ZLITNI, Abdul Hafiz; a.k.a. ZLITNI, Abdulhafid; a.k.a. ZLITNI, Abdulhafid Mahmoud); DOB 1938; POB Tripoli, Libya; Secretary of the General People’s Committee for Finance and Planning; Secretary of the General People’s Committee for Planning and Finance; Finance Minister; Director and Deputy Chairman of the Libyan Investment Authority (individual) [LIBYA2]

BASHIR, Bashir Saleh (a.k.a. SALEH, Bachir; a.k.a. SALEH, Bashir); DOB 1946; POB Traghen, Libya; Head of Cabinet of Leader Muammar Gaddafi; Chief of Staff; Chairman of Libya Africa Investment Portfolio (individual) [LIBYA2]

GADDAFI INTERNATIONAL CHARITY AND DEVELOPMENT FOUNDATION (a.k.a. GADDAFI INTERNATIONAL FOUNDATION FOR CHARITY ORGANISATIONS), Hay Elandadlus – Jian St, P.O. Box 1101, Tripoli, Libya; 22, Rue Henri-Mussard, Geneva 1208, Switzerland; Email Address info@gicdf.org; Registration ID CH-660.0.699.004-7 (Switzerland); Website http://www.gicdf.org; Telephone No. (218) (0)214778301; Telephone No. (022) 7363030; Fax No. (218) (0)214778766; Fax No. (022) 7363196 [LIBYA2]

GADDAFI INTERNATIONAL FOUNDATION FOR CHARITY ORGANISATIONS (a.k.a. GADDAFI INTERNATIONAL CHARITY AND DEVELOPMENT FOUNDATION), Hay Elandadlus – Jian St, P.O. Box 1101, Tripoli, Libya; 22, Rue Henri-Mussard, Geneva 1208, Switzerland; Email Address info@gicdf.org; Registration ID CH-660.0.699.004-7 (Switzerland); Website http://www.gicdf.org; Telephone No. (218) (0)214778301; Telephone No. (022) 7363030; Fax No. (218) (0)214778766; Fax No. (022) 7363196 [LIBYA2]

GHANEM, Shokri (a.k.a. GHANEM, Shukri Mohammed); DOB 9 Oct 1942; POB Tripoli, Libya; Oil Minister; Chairman of the National Oil Company of Libya (individual) [LIBYA2]

GHANEM, Shukri Mohammed (a.k.a. GHANEM, Shokri); DOB 9 Oct 1942; POB Tripoli, Libya; Oil Minister; Chairman of the National Oil Company of Libya (individual) [LIBYA2]

KHALED, Al-Tohamy (a.k.a. AL-TUHAMI, Khaled; a.k.a. KHALED, al-Tuhami; a.k.a. KHALED, Tohami); DOB 1946; POB Genzur, Libya; General; Director of the Internal Security Office (individual) [LIBYA2]

KHALED, al-Tuhami (a.k.a. AL-TUHAMI, Khaled; a.k.a. KHALED, Al-Tohamy; a.k.a. KHALED, Tohami); DOB 1946; POB Genzur, Libya; General; Director of the Internal Security Office (individual) [LIBYA2]

KHALED, Tohami (a.k.a. AL-TUHAMI, Khaled; a.k.a. KHALED, Al-Tohamy; a.k.a. KHALED, alTuhami); DOB 1946; POB Genzur, Libya; General; Director of the Internal Security Office (individual) [LIBYA2]

MAHMUDI, Baghdadi (a.k.a. AL BAGHDADI, Ali Al-Mahmoudi); DOB 1950; POB Al Jamil, Libya; Prime Minister (individual) [LIBYA2]

SALEH, Bachir (a.k.a. BASHIR, Bashir Saleh; a.k.a. SALEH, Bashir); DOB 1946; POB Traghen, Libya; Head of Cabinet of Leader Muammar Gaddafi; Chief of Staff; Chairman of Libya Africa Investment Portfolio (individual) [LIBYA2]

SALEH, Bashir (a.k.a. BASHIR, Bashir Saleh; a.k.a. SALEH, Bachir); DOB 1946; POB Traghen, Libya; Head of Cabinet of Leader Muammar Gaddafi; Chief of Staff; Chairman of Libya Africa Investment Portfolio (individual) [LIBYA2]

WAATASEMU CHARITY ASSOCIATION, Omar Almukhtar Street, Tripoli, Libya; Email Address info@waatasemu.org; Website http://waatasemu.org.ly; Telephone No. (218) 21 273343326; Fax No. (218) 21 253343328 [LIBYA2]

ZLEITNI, Abdel-Hafez (a.k.a. AL-ZULAYTINI, Abd-Al-Hafid Mahmud; a.k.a. ZLITNI, Abdelhafidh; a.k.a. ZLITNI, Abdul Hafid; a.k.a. ZLITNI, Abdul Hafiz; a.k.a. ZLITNI, Abdulhafid; a.k.a. ZLITNI, Abdulhafid Mahmoud); DOB 1938; POB Tripoli, Libya; Secretary of the General People’s Committee for Finance and Planning; Secretary of the General People’s Committee for Planning and Finance; Finance Minister; Director and Deputy Chairman of the Libyan Investment Authority (individual) [LIBYA2]

ZLITNI, Abdelhafidh (a.k.a. AL-ZULAYTINI, AbdAl-Hafid Mahmud; a.k.a. ZLEITNI, Abdel-Hafez; a.k.a. ZLITNI, Abdul Hafid; a.k.a. ZLITNI, Abdul
Hafiz; a.k.a. ZLITNI, Abdulhafid; a.k.a. ZLITNI, Abdulhafid Mahmoud); DOB 1938; POB Tripoli, Libya; Secretary of the General People’s
Committee for Finance and Planning; Secretary of the General People’s Committee for Planning and Finance; Finance Minister; Director and Deputy Chairman of the Libyan Investment Authority (individual) [LIBYA2]

ZLITNI, Abdul Hafid (a.k.a. AL-ZULAYTINI, AbdAl-Hafid Mahmud; a.k.a. ZLEITNI, Abdel-Hafez; a.k.a. ZLITNI, Abdelhafidh; a.k.a. ZLITNI, Abdul
Hafiz; a.k.a. ZLITNI, Abdulhafid; a.k.a. ZLITNI, Abdulhafid Mahmoud); DOB 1938; POB Tripoli, Libya; Secretary of the General People’s Committee for Finance and Planning; Secretary of the General People’s Committee for Planning and Finance; Finance Minister; Director and Deputy Chairman of the Libyan Investment Authority (individual) [LIBYA2]

ZLITNI, Abdul Hafiz (a.k.a. AL-ZULAYTINI, AbdAl-Hafid Mahmud; a.k.a. ZLEITNI, Abdel-Hafez; a.k.a. ZLITNI, Abdelhafidh; a.k.a. ZLITNI, Abdul
Hafid; a.k.a. ZLITNI, Abdulhafid; a.k.a. ZLITNI, Abdulhafid Mahmoud); DOB 1938; POB Tripoli, Libya; Secretary of the General People’s Committee for Finance and Planning; Secretary of the General People’s Committee for Planning and Finance; Finance Minister; Director and Deputy Chairman of the Libyan Investment Authority (individual) [LIBYA2]

ZLITNI, Abdulhafid (a.k.a. AL-ZULAYTINI, Abd-AlHafid Mahmud; a.k.a. ZLEITNI, Abdel-Hafez; a.k.a. ZLITNI, Abdelhafidh; a.k.a. ZLITNI, Abdul
Hafid; a.k.a. ZLITNI, Abdul Hafiz; a.k.a. ZLITNI, Abdulhafid Mahmoud); DOB 1938; POB Tripoli, Libya; Secretary of the General People’s Committee for Finance and Planning; Secretary of the General People’s Committee for Planning and Finance; Finance Minister; Director and Deputy Chairman of the Libyan Investment Authority (individual) [LIBYA2]

ZLITNI, Abdulhafid Mahmoud (a.k.a. ALZULAYTINI, Abd-Al-Hafid Mahmud; a.k.a. ZLEITNI, Abdel-Hafez; a.k.a. ZLITNI, Abdelhafidh; a.k.a. ZLITNI, Abdul Hafid; a.k.a. ZLITNI, Abdul Hafiz; a.k.a. ZLITNI, Abdulhafid); DOB 1938; POB Tripoli, Libya; Secretary of the General People’s Committee for Finance and Planning; Secretary of the General People’s Committee for Planning and Finance; Finance Minister; Director and Deputy Chairman of the Libyan Investment Authority (individual) [LIBYA2]

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“4/8/2011
Libya’s Prime Minister, Oil Minister, Finance Minister, Director of Internal Security Office, and Qadhafi’s Chief of Staff Targeted for Sanctions

WASHINGTON – Increasing pressure on the Qadhafi regime, the U.S. Department of the Treasury today announced the designation of five senior Libyan government officials and two entities owned or controlled by children of Muammar Qadhafi pursuant to Executive Order (E.O.) 13566.

“We will continue to expose and impose sanctions on senior Libyan government officials who choose to remain at Qadhafi’s side,” said Acting Under Secretary for Terrorism and Financial Intelligence David S. Cohen. “They have a choice to make, and we will make that choice as stark as possible.”

President Obama signed E.O. 13566 on February 25, 2011, freezing the assets of the Qadhafi regime following its use of violence against civilians and human rights abuses in Libya and safeguarding the assets of the people of Libya from expropriation by Qadhafi. To date, more than $34 billion in Government of Libya assets have been frozen, and 19 individuals, including senior government officials and family members of Qadhafi, have been designated for sanctions under E.O. 13566. As a result of today’s action, any assets of the designees subject to U.S. jurisdiction are frozen, and U.S. persons are prohibited from engaging in business with them.

The following individuals were designated today for being senior officials of the Government of Libya:

Ali al-Mahmoudi Al Baghdadi: Libya’s Prime Minister and member of Muammar Qadhafi’s inner circle.
Shukri Ghanem: Libya’s Oil Minister and Chairman of the National Oil Company of Libya (NOC), identified by Treasury on March 15 as subject to sanctions for being owned or controlled by the Government of Libya. Ghanem has full responsibility for policies and operations of Libya’s petroleum sector.
Abdulhafid Zlitni: Secretary of the General People’s Committee for Finance and Planning, Libya’s equivalent of Finance Minister. Zltini is currently acting as temporary head of the Central Bank of Libya. He was previously NOC Chairman.

Tohami Khaled: Director of Libya’s Internal Security Office.

Bashir Saleh: Head of Cabinet – or Chief of Staff – to Muammar Qadhafi. He is also the Chairman of the Libya Africa Investment Portfolio (LAIP), identified by Treasury on March 15 as subject to sanctions for being owned or controlled by the Government of Libya.

The Gaddafi International Charity and Development Foundation and the Waatasemu Charity Association were also designated today. The Gaddafi International Charity and Development Foundation is a Geneva-registered organization founded in Libya in 1998 and incorporated in Switzerland in 2004. It was designated for being owned and controlled by Mummar Qadhafi’s son Saif Al Islam Qadhafi, who is the foundation’s President and a board member. Saif Al Islam Qadhafi was listed by President Obama in the Annex to E.O. 13566, along with his father. Waatasemu Charity Association was designated for being controlled by Aisha Qadhafi, Muammar Qadhafi’s daughter and Secretary General of the Libya-based organization. Aisha was also listed in the Annex to E.O. 13566.

Identifying Information:

Individual: AL BAGHDADI, Ali Al-Mahmoudi
AKA: MAHMUDI, Baghdadi
DOB: 1950
POB: Al Jamil, Libya

Individual: GHANEM, Shukri Mohammed
AKA: GHANEM, Shokri
DOB: October 9, 1942
POB: Tripoli, Libya

Individual: KHALED, Tohami
AKA: AL-TUHAMI, Khaled
AKA: KHALED, Al-Tohamy
AKA: KHALED, al-Tuhami
DOB: 1946
POB: Genzur, Libya

Individual: SALEH, Bachir
AKA: BASHIR, Bashir Saleh
AKA: SALEH, Bashir
DOB: 1946
POB: Traghen, Libya

Individual: ZLITNI, Abdulhafid
AKA: AL-ZULAYTINI, Abd-Al-Hafid Mahmud
AKA: ZLEITNI, Abdel-Hafez
AKA: ZLITNI, Abdelhafidh
AKA: ZLITNI, Abdul Hafid
AKA: ZLITNI, Abdul Hafiz
AKA: ZLITNI, Abdulhafid Mahmoud
DOB: 1938
POB: Tripoli, Libya

Entity: Gaddafi International Charity and Development Foundation
AKA: Gaddafi International Foundation for Charity Organisations
Address: Hay Elandadlus – Jian St, P.O. Box 1101, Tripoli, Libya
Alt Address: 22 Rue Henri-Mussard, Geneva 1208, Switzerland

Entity: Waatasemu Charity Association
Address: Omar Almukhtar Street, Tripoli, Libya​”

See OFAC’s Press Release here.

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Douglas McNabb and other members of the firm practice and write extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN List Removal.

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

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Recent OFAC Actions: LIBYA2 Designations Removed From OFAC’s SDN list

April 4, 2011

On April 4, 2011, OFAC removed one individual (and 3 assumed names) from the LIBYA2 Specially Designated Nationals List (SDN List):

KOUSA, Mousa (a.k.a. KOUSSA, Moussa; a.k.a. KUSA, Musa; a.k.a. KUSSA, Mussa); DOB circa 1949; Foreign Minister; Secretary of the General
People’s Committee for Foreign Liaison and International Cooperation (individual) [LIBYA2]

KOUSSA, Moussa (a.k.a. KOUSA, Mousa; a.k.a. KUSA, Musa; a.k.a. KUSSA, Mussa); DOB circa 1949; Foreign Minister; Secretary of the General
People’s Committee for Foreign Liaison and International Cooperation (individual) [LIBYA2]

KUSA, Musa (a.k.a. KOUSA, Mousa; a.k.a. KOUSSA, Moussa; a.k.a. KUSSA, Mussa); DOB circa 1949; Foreign Minister; Secretary of the
General People’s Committee for Foreign Liaison and International Cooperation (individual) [LIBYA2]

KUSSA, Mussa (a.k.a. KOUSA, Mousa; a.k.a. KOUSSA, Moussa; a.k.a. KUSA, Musa); DOB circa 1949; Foreign Minister; Secretary of the
General People’s Committee for Foreign Liaison and International Cooperation (individual) [LIBYA2]

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Douglas McNabb and other members of the firm practice and write extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN List Removal.

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

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