Douglas McNabb discussed today’s OFAC designation of Afghanistan and U.A.E. individuals and businesses.
As of today, the Office of Foreign Assets Control (OFAC) designated 9 individuals and 7 entities on the Specially Designated Nationals List (SDN List). Placement on the SDN List acts as a freeze on any U.S. financial assets the individuals or entities may have. More significantly, if the individuals or entities have assets in a U.S. foreign correspondent bank (a foreign bank with financial ties to the U.S.), those assets are frozen as well.
An SDN designation is the means by which the U.S. government uses to block individuals or entities from accessing any funds that may conceivably enter, or already exist, in the U.S. financial system. Further, those under U.S. jurisdiction, such as a person or corporation, are forbidden from engaging in any transaction with those designated.
The individuals and entities today were designated under “SDNTK.” Meaning, OFAC believes they are involved in narcotics dealings and has designated them under the Foreign Narcotics Kingpin Designation Act. OFAC may also designate alleged narcotics traffickers under Executive Order 12978, however those designations target individuals and entities from Columbia. If designated under Order 12978, the individual or entity will be designated under “SDNT.”
The individuals designated as of today include:
AZIMI, Haji Mohammad Rafi (a.k.a. AZIMI, Haji Muhammad Rafi; a.k.a. RAFI, Abdul);
BARAKZAI ANSARI, Haji Abdullah (a.k.a. ANSARI, Haji Abdullah; a.k.a. BARAKZAI, Haji Abdullah);
HAJI ABDUL QAYOUM, Eissa Jan (a.k.a. HAJI ABDUL QAYOUM, Eisa Jan; a.k.a. HAJI ABDUL QAYOUM, Eisa Jon);
HAKIMI, Ahmad Shah;
JAN, Haji Mohammad (a.k.a. BIN KUL MOHAMMED, Mohammad Jan);
KHAN, Haji Mohammad;
MOHAMMAD AFZAL, Rahmatullah;
NOOR, Haji Mohammad (a.k.a. MOHAMED KOL, Mohammed Noor; a.k.a. MOHAMMED KUL, Mohammed Nour);
The following entities have been added to the SDN List as of today:
AHMAD SHAH MONEY EXCHANGE (a.k.a. AHMAD SHAH HAKIMI MONEY EXCHANGE; a.k.a. HAKIMI MONEY EXCHANGE; a.k.a. SHAH HAKIMI MONEY EXCHANGE) (Afghanistan);
AL ADAL EXCHANGE (United Arab Emirates);
CONNECT TELECOM GENERAL TRADING LLC (United Arab Emirates);
GREEN LEAF GENERAL TRADING LLC (f.k.a. GREEN LEAF TRADING LLC) (United Arab Emirates);
MUSHTAQ SHAHEEN CONSTRUCTION AND ROADMAKING COMPANY (a.k.a. MUSHTAQ SHAHEEN LTD) (Afghanistan);
NEW ANSARI LTD (Afghanistan);
NEW ANSARI MONEY EXCHANGE (a.k.a. NAWI ANSARI LTD; a.k.a. NEW ANSARI COMPANY; a.k.a. NEW ANSARI MONEY SERVICES PROVIDER) (Afghanistan).
View OFAC’s press release here.
Removal from the SDN List is possible, but it requires complex litigation and may take several years.
Douglas McNabb and other members of the firm practice and write extensively on matters involving Federal Criminal Defense, INTERPOL Litigation, International Extradition and OFAC SDN Litigation.
The author of this blog is Douglas McNabb. Please feel free to contact him directly at email@example.com or at one of the offices listed above.