“US Sanctions Iranian Venezuelan Bi-National Bank”

May 10, 2013

Latin American Herald Tribune on May 10, 2013 released the following:

“US Treasury Identifies Front Company and Vessels Attempting to Obscure Iranian Oil Deals Using Ship-to-Ship Transfers and Designates Venezuelan Iranian Bank

WASHINGTON, D.C. – The U.S. Department of the Treasury placed a Venezuelan Iranian Bank and an Iranian shipping company which were being used to circumvent international financial sanctions on the Office of Foreign Assets Control list.

The Treasury Department also imposed sanctions against Iranian Venezuelan Bi-National Bank (IVBB). IVBB was designated pursuant to Executive Order 13382, which targets proliferators of weapons of mass destruction (WMD) and their supporters, for engaging in financial transactions on behalf of the previously sanctioned Export Development Bank of Iran (EDBI).

The Iranian Venezuelan Bi-National Bank (IVBB) is being designated for its activities on behalf of the Export Development Bank of Iran (EDBI). EDBI was designated under E.O. 13382 on October 22, 2008, for providing financial services to Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL).

IVBB has been processing funds transfers on behalf of EDBI since at least January 2012. EDBI has used IVBB to act as a proxy to fund export activities and to transfer millions of dollars worth of funds from China’s Bank of Kunlun to EDBI. Additionally, senior EDBI staff is entitled to authorize transaction instructions to Bank of Kunlun on behalf of IVBB.

Bank of Kunlun was sanctioned by the U.S. Treasury Department under Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) on July 31, 2012, for providing financial services to more than six Iranian banks that were designated by the U.S. in connection with Iran’s WMD programs or its support for international terrorism. Prior to the sanctions imposed against it under the CISADA, Bank of Kunlun was engaged in a significant amount of direct of business with EDBI, handling the equivalent of tens of millions of dollars worth of funds for EDBI.

IVBB was originally established as a joint venture between Iran and Venezuela, and EDBI was the Iranian party tasked with creating the joint venture with Venezuela. However, there is no evidence Venezuela retains any ties to this bank.

As part of the Treasury Department’s continuing vigilance against Iran’s efforts to use front companies and deceptive business practices to sell their oil on the international market, today Treasury identified Sambouk Shipping FZC as subject to sanctions under Executive Order (E.O.) 13599, which, among other things, targets the Government of Iran (GOI) and persons acting for or on behalf of the GOI. Sambouk Shipping is tied to Dr. Dimitris Cambis who, along with a network of front companies, were sanctioned in March 2013 under E.O. 13599 and the Iran Threat Reduction Act and Syria Human Rights Act of 2012 (TRA) after the U.S. government uncovered Dr. Cambis’s scheme to evade international oil sanctions against Iran. In an attempt to continue his scheme, Dr. Cambis is using the recently formed Sambouk Shipping to manage eight of the vessels that he operates on behalf of the National Iranian Tanker Company (NITC). These vessels have been used to execute ship-to-ship transfers of Iranian oil in the Persian Gulf. These transfers are intended to facilitate deceptive sales of Iranian oil by obscuring the origin of that oil.

“As Iran becomes increasingly isolated from the international financial system and energy markets, it is turning increasingly to convoluted schemes and shady actors to maintain its access to the global financial system,” said Under Secretary for Terrorism and Financial Intelligence David S. Cohen. “As long as Iran tries to evade our sanctions, we will continue to expose their deceptive maneuvers.”

Treasury’s Office of Foreign Assets Control is also updating its list of Specially Designated Nationals and Blocked Persons (SDN List) entries today for eight vessels blocked due to the interest of National Iranian Tanker Company in the vessels. Since their original identification these vessels have been renamed and/or reflagged. Treasury is also identifying eight previously unidentified vessels as blocked property in which NITC has an interest. Including today’s additions, Treasury has identified 64 vessels as blocked property in which NITC has an interest.

U.S. persons are generally prohibited from engaging in any transactions with the entities listed today, and any assets those entities may have subject to U.S. jurisdiction are frozen.

Identifying Information

Name: Iranian-Venezuelan Bi-National Bank
Address: Tosee Building Ground Floor, Bokharest Street 44-46, Tehran, Iran
SWIFT/BIC: IVBBIRT1

Name: Sambouk Shipping FZC
Address: FITCO Building No. 3, Office 101, 1st Floor, P.O. Box 50044, Fujairah, United Arab Emirates
Alternate Address: Office 1202, Crystal Plaza, PO Box 50044, Buhaira Corniche, Sharjah, United Arab Emirates

Newly-Identified Vessels:

Name: Atlantis
Vessel Type: Crude Oil Tanker
Flag: Tanzania
IMO Number: 9569621

Name: Badr
Vessel Type: Utility Vessel
Flag: Iran
IMO Number: 8407345

Name: Demos
Vessel Type: Crude Oil Tanker
Flag: Tanzania
IMO Number: 9569683

Name: Infinity
Vessel Type: Crude Oil Tanker
Flag: Tanzania
IMO Number: 9569671

Name: Justice
Vessel Type: Crude Oil Tanker
Flag: None Identified
IMO Number: 9357729

Name: Sunrise
Vessel Type: LPG Tanker
Flag: None Identified
IMO Number: 9615092

Name: Skyline
Vessel Type: Crude Oil Tanker
Flag: Tanzania
IMO Number: 9569669

Name: Younes
Vessel Type: Platform Supply Ship
Flag: Iran
IMO Number: 8212465”

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Douglas McNabb – McNabb Associates, P.C.’s
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OFAC Litigation – SDN List Removal

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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.

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“Colombian Soccer Team Removed From U.S. Treasury’s Drug List”

April 4, 2013

Fox News Latino on April 3, 2013 released the following:

“Lance Armstrong and Barry Bonds have got nothing on Colombia’s America de Cali soccer team.

EPO and human growth hormones are child’s play compared to the Cali squad, which has been on the United State’s list of Specially Designated Nationals and Blocked Persons (SDN List) since 1999, after the U.S. claimed the team was under the ownership of Cali drug cartel leaders Miguel and Gilberto Rodriguez Orejuela.

While Toronto Blue Jays’ outfielder Melky Cabrera’s suspension and redemption only lasted 50 games, America de Cali had to wait 14 seasons for their chance, as the U.S. Treasury Department finally removed Wednesday the team from SDN list.

“Today’s lifting of the designation of America de Cali is a testament to the enormous efforts made in recent years by both the team and the Colombian government to completely break with the criminal influences that have overshadowed the team in the past,” said David S. Cohen, Under Secretary for Terrorism and Financial Intelligence, in a press statement.

America de Cali’s front office recently underwent an enormous restructuring and bankruptcy deal, with oversight from the Colombian government to monitor that the team had cut all ties with the former drug lords.

Both Rodríguez Orejuela brothers were arrested and then extradited to the U.S. in 2006, where they pleaded guilty in Miami to charges of conspiracy to import cocaine into the United States.

During the 1980s and 1990s, Colombian drug cartels became deeply involved in the country’s professional soccer league. Besides America de Cali, Medellín’s Atlético Nacional was heavily supported, both financially and on a fan basis, by famed cartel leader Pablo Escobar.

The Medellín Cartel and the Cali Cartel used the teams in a sometimes friendly, sometimes not-so-friendly rivalry between the two groups of narcos.

Besides the removal of the team from the SDN list, the Treasury Department praised the work of the Colombian government and promised to continue working with the Latin American nation to thwart drug cartels.

“As we continue our work with the Colombian government to combat the threat of narcotics trafficking, we will use our authorities to target those responsible for illicit behavior just as we will lift sanctions in cases where there has been a concrete change in behavior,” Cohen said.”

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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:

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Obama Signs Executive Order Putting Tougher Sanctions on Iran

February 7, 2012

The Cypress Times on February 6, 2012 released the following:

“WASHINGTON, DC – Today, President Obama signed an Executive Order (E.O.) that takes a number of actions in furtherance of the Administration’s Iran sanctions program, including measures to implement section 1245 of the National Defense Authorization Act (NDAA). Among other things, the E.O. freezes all property of the Central Bank of Iran and all other Iranian financial institutions, as well as all property of the Government of Iran, further tightening the already broad-based and stringent U.S. sanctions on Iran.

These actions underscore the Administration’s resolve to hold the Iranian regime accountable for its failure to meet its international obligations. Iran now faces an unprecedented level of pressure due to intensified sanctions applied by the United States and complementary actions by many others around the world. The new E.O. issued today reemphasizes this Administration’s message to the Government of Iran – it will face ever-increasing economic and diplomatic pressure until it addresses the international community’s well-founded and well-documented concerns regarding the nature of its nuclear program.

Additional information describing the implementation of section 1245 of the NDAA pursuant to the authorities delegated under this E.O. will be made available in the near term.

Sanctions under the New Executive Order:

On February 5, President Obama signed a new E.O. effective at 12:01 a.m. on February 6, that blocks (i.e., “freezes”) all property of the Government of Iran as well as all property of Iranian financial institutions, including the Central Bank of Iran.

1. The E.O. blocks all property and interests in property of the Government of Iran, the Central Bank of Iran and all Iranian financial institutions (regardless of whether the financial institution is part of the Government of Iran) that are in the United States, that come within the United States, or that come within the possession or control of U.S. persons. Previously, U.S. persons were required to “reject,” rather than “block,” Iranian transactions.

  • Under the order, the Government of Iran, the Central Bank of Iran, and all Iranian financial institutions are now blocked (i.e. their assets within the jurisdiction of U.S. persons are frozen).
  • The U.S. sanctions in place since 1995 have required most transactions involving the Government of Iran, the Central Bank of Iran and all Iranian financial institutions to be rejected – that is, they could not pass through the U.S. financial system, but instead were turned back. Under the new E.O., transactions involving the Government of Iran, the Central Bank of Iran and all Iranian financial institutions that previously would have been rejected will now be blocked.
  • All entities that meet the existing definition of “Government of Iran,” such as Iranian ministries, state-owned entities and commercial firms owned or controlled by the Government of Iran, are blocked. This includes entities bearing the [IRAN] tag on the Treasury Department’s Office of Foreign Assets Control’s (OFAC) List of Specially Designated Nationals and Blocked Persons (SDN List). Transactions by U.S. persons involving such entities are now blocked unless exempt or otherwise authorized. OFAC will continue to update the SDN List and may add, delete, or edit existing entries as appropriate.
  • The E.O. does not change the sanctions that may be applied against foreign financial institutions engaging in arms-length transactions with certain Iranian financial institutions, including the Central Bank of Iran. Those foreign financial institutions remain at risk of U.S. sanctions if they engage in certain significant financial transactions with the Central Bank of Iran or certain other designated Iranian financial institutions pursuant to the NDAA, or the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA).

2. Treasury is issuing general licenses to maintain existing authorizations for certain transactions that advance U.S. foreign policy interests.

  • Persons who currently use general or specific licenses from OFAC for transactions involving the Government of Iran or Iranian financial institutions should consult the OFAC website for new general licenses and other information on whether those transactions remain authorized under the new E.O.

Delegations of Authority under the New Executive Order:

The E.O. also delegates other authorities provided in section 1245(d) of the NDAA.

  • The E.O. delegates a number of other authorities provided in section 1245(d) of the NDAA, primarily to the Departments of the Treasury and State. These delegations will facilitate the implementation of section 1245 of the NDAA.
  • Additional information describing the implementation of the NDAA under these delegated authorities will be made available in the near term.”

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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 and OFAC SDN Sanctions 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.