The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC): “Treasury Removes Sanctions on Iraqi Bank”

May 17, 2013

The U.S. Department of the Treasury on May 17, 2013 released the following:

Action Follows a Verified Change of Behavior from the Elaf Islamic Bank

WASHINGTON – The Department of the Treasury today lifted sanctions against the Elaf Islamic Bank in Iraq following the bank’s significant and demonstrated change in behavior.

On July 31, 2012 the Treasury Department imposed sanctions under the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA), against Elaf Islamic Bank, a privately-owned Iraqi financial institution, for knowingly facilitating significant transactions and providing significant financial services for the U.S. and EU-designated Export Development Bank of Iran (EDBI). Following the CISADA finding, Elaf immediately engaged the Treasury Department and began an intensive course of action to stop the conduct that led to the CISADA sanction, including freezing EDBI accounts at Elaf and reducing its overall exposure to the Iranian financial sector. Following today’s action U.S. financial institutions are once again permitted to open or maintain correspondent accounts or payable-through accounts in the United States for Elaf Islamic Bank.

“Today we welcome Elaf Islamic Bank back into the U.S. financial system, and we urge other designated individuals and entities around the world to follow its positive example. As today’s delisting demonstrates, our sanctions are flexible and can be lifted if the conduct that led to the sanction terminates,” said Under Secretary for Terrorism and Financial Intelligence David S. Cohen. “As we increase our sanctions against Iran, we will continue to target any financial institution that works with designated Iranian banks or attempts to assist Iran in evading sanctions.”

Sanctions may be, and regularly are, lifted when circumstances warrant, which includes ceasing the sanctionable activity. Any sanctioned party may petition OFAC for sanctions to be lifted. In general, demonstrating changes in circumstances or behavior are essential to the lifting of sanctions.

Treasury will continue to use all tools at its disposal to target entities or individuals engaging in sanctionable activity related to Iran. CISADA was signed into law by President Obama in July 2010. Among other things, CISADA provides the Secretary of the Treasury with the authority to impose strict conditions on, or prohibit the opening or maintaining of, correspondent accounts or payable-through accounts in the United States for foreign financial institutions that knowingly facilitate a significant transaction or provide significant financial services for a person whose property and interests in property are blocked under the International Emergency Economic Powers Act in connection with Iran’s proliferation of weapons of mass destruction (WMD) or delivery systems for WMD, or for Iran’s support for international terrorism.”

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

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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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“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
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.

————————————————————–

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Weapons of Mass Destruction Proliferators [NPWMD] and [IRGC] Entries Added to OFAC’s SDN List on March 28, 2012

March 28, 2012

Today, OFAC has added [NPWMD] and [IRGC] Entries to the Specially Designated Nationals List (SDN List):

The following [NPWMD] entries have been added to OFAC’s SDN list:

EZATI, Ali (a.k.a. EZZATI, Ali); DOB 5 Jun 1963; Passport Z19579335 (Iran) (individual) [NPWMD]

EZZATI, Ali (a.k.a. EZATI, Ali); DOB 5 Jun 1963; Passport Z19579335 (Iran) (individual) [NPWMD]

MALSHIP SHIPPING AGENCY LTD., 143/1 Tower Road, Sliema, Malta; Commercial Registry Number C43447 (Malta) [NPWMD]

MODALITY LIMITED, 2, Liza, Fl. 5, Triq IlPrekursur, Madliena, Swieqi, Malta; Commercial Registry Number C49549 (Malta) [NPWMD]

RASOOL, Seyed Alaeddin Sadat; DOB 23 Jul 1965 (individual) [NPWMD]

The following [NPWMD][IRGC] entries have been added to OFAC’s SDN list:

DEEP OFFSHORE TECHNOLOGY COMPANY PJS, 1st Floor, Sadra Building, No. 3, Shafagh Street, Shahid Dadman Boulevard, Paknejad Boulevard, 7th Phase, Shahrake-E-Quds, Tehran, Iran [NPWMD] [IRGC]

IRAN MARINE INDUSTRIAL COMPANY SSA (a.k.a. IRAN MARINE INDUSTRIAL COMPANY, SADRA; a.k.a. IRAN SADRA; a.k.a. IRAN SHIP BUILDING CO.; a.k.a. SADRA; a.k.a. SHERKATE SANATI DARYAI IRAN), 3rd Floor Aftab Building, No. 3 Shafagh Street, Dadman Blvd, Phase 7, Shahrak Ghods, P.O. Box 14665-495, Tehran, Iran; Office E-43 Torre E- Piso 4, Centrao Commercial Lido Av., Francisco de Miranda, Caracas, Venezuela; Website http://www.sadra.ir [NPWMD] [IRGC]

IRAN MARINE INDUSTRIAL COMPANY, SADRA (a.k.a. IRAN MARINE INDUSTRIAL COMPANY SSA; a.k.a. IRAN SADRA; a.k.a. IRAN SHIP BUILDING CO.; a.k.a. SADRA; a.k.a. SHERKATE SANATI DARYAI IRAN), 3rd Floor Aftab Building, No. 3 Shafagh Street, Dadman Blvd, Phase 7, Shahrak Ghods, P.O. Box 14665-495, Tehran, Iran; Office E-43 Torre E- Piso 4, Centrao Commercial Lido Av., Francisco de Miranda, Caracas, Venezuela; Website http://www.sadra.ir [NPWMD] [IRGC]

IRAN SADRA (a.k.a. IRAN MARINE INDUSTRIAL COMPANY SSA; a.k.a. IRAN MARINE INDUSTRIAL COMPANY, SADRA; a.k.a. IRAN SHIP BUILDING CO.; a.k.a. SADRA; a.k.a. SHERKATE SANATI DARYAI IRAN), 3rd Floor Aftab Building, No. 3 Shafagh Street, Dadman Blvd, Phase 7, Shahrak Ghods, P.O. Box 14665-495, Tehran, Iran; Office E-43 Torre E- Piso 4, Centrao Commercial Lido Av., Francisco de Miranda, Caracas, Venezuela; Website http://www.sadra.ir [NPWMD] [IRGC]

IRAN SHIP BUILDING CO. (a.k.a. IRAN MARINE INDUSTRIAL COMPANY SSA; a.k.a. IRAN MARINE INDUSTRIAL COMPANY, SADRA; a.k.a. IRAN SADRA; a.k.a. SADRA; a.k.a. SHERKATE SANATI DARYAI IRAN), 3rd Floor Aftab Building, No. 3 Shafagh Street, Dadman Blvd, Phase 7, Shahrak Ghods, P.O. Box 14665-495, Tehran, Iran; Office E-43 Torre E- Piso 4, Centrao Commercial Lido Av., Francisco de Miranda, Caracas, Venezuela; Website http://www.sadra.ir [NPWMD] [IRGC]

SADRA (a.k.a. IRAN MARINE INDUSTRIAL COMPANY SSA; a.k.a. IRAN MARINE INDUSTRIAL COMPANY, SADRA; a.k.a. IRAN SADRA; a.k.a. IRAN SHIP BUILDING CO.; a.k.a. SHERKATE SANATI DARYAI IRAN), 3rd Floor Aftab Building, No. 3 Shafagh Street, Dadman Blvd, Phase 7, Shahrak Ghods, P.O. Box 14665-495, Tehran, Iran; Office E-43 Torre E- Piso 4, Centrao Commercial Lido Av., Francisco de Miranda, Caracas, Venezuela; Website http://www.sadra.ir [NPWMD] [IRGC]

SHERKATE SANATI DARYAI IRAN (a.k.a. IRAN MARINE INDUSTRIAL COMPANY SSA; a.k.a. IRAN MARINE INDUSTRIAL COMPANY, SADRA; a.k.a. IRAN SADRA; a.k.a. IRAN SHIP BUILDING CO.; a.k.a. SADRA), 3rd Floor Aftab Building, No. 3 Shafagh Street, Dadman Blvd, Phase 7, Shahrak Ghods, P.O. Box 14665-495, Tehran, Iran; Office E-43 Torre E- Piso 4, Centrao Commercial Lido Av., Francisco de Miranda, Caracas, Venezuela; Website http://www.sadra.ir [NPWMD] [IRGC]

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Treasury Announces Additional Sanctions Against Iranian Engineering and Shipping Firms

3/28/2012

WASHINGTON – The U.S. Department of the Treasury announced today additional sanctions against two entities connected to the network of the Islamic Revolutionary Guard Corps (IRGC) and two individuals and two entities affiliated with Iran’s national maritime carrier, the Islamic Republic of Iran Shipping Lines (IRISL). Today’s actions further expose IRGC and IRISL continued involvement in illicit activities and deceptive behavior.

Pursuant to Executive Order (E.O.) 13382 – an authority aimed at freezing the assets of proliferators of weapons of mass destruction (WMD) and their supporters and thereby isolating them from the U.S. financial and commercial systems – Treasury today designated the following entities and individuals.

  • Iran Maritime Industrial Company SADRA (SADRA), an entity owned by the IRGC’s Khatam al-Anbiya
  • Deep Offshore Technology PJS, a subsidiary of SADRA
  • Malship Shipping Agency Ltd., an IRISL affiliate
  • Modality Limited, an IRISL affiliate
  • Seyed Alaeddin Sadat Rasool, an IRISL official
  • Ali Ezati, an IRISL official

“By designating the individuals and entities today, Treasury is sending a clear signal to the international community that Iran’s attempts to evade international sanctions will not go unnoticed. We will continue to target the Iranian regime and specifically the IRGC as it attempts to continue its nefarious infiltration of the Iranian economy,” said Adam Szubin, Director of Treasury’s Office of Foreign Assets Control (OFAC).

The IRGC continues to be a primary focus of U.S. and international sanctions against Iran because of the central role the IRGC plays in Iran’s missile and nuclear programs, its support for terrorism, and its involvement in serious human rights abuses. Similarly, IRISL has played a key role in Iran’s efforts to advance its missile programs and transport other military cargoes. The IRGC has continued to expand its control over the Iranian economy – in particular in the defense production, construction, and oil and gas industries – subsuming increasing numbers of Iranian businesses and pressing them into service in support of the IRGC’s illicit conduct.

IRGC Designations

SADRA which has offices in Iran and Venezuela is being designated for being owned or controlled by Khatam al-Anbiya. OFAC designated Khatam al-Anbiya in October 2007 under E.O. 13382 as an engineering arm of the IRGC that the IRGC uses to generate income and fund its operations. The U.S. Department of State designated the IRGC in October 2007 under E.O. 13382 Section (1)(a)(ii), for engaging, or attempting to engage, in activities or transactions that have materially contributed to, or pose a risk of materially contributing to, the proliferation of WMD or their means of delivery.

Deep Offshore Technology PJS is being designated today under E.O. 13382 because it is wholly-owned by SADRA.

Treasury has also determined that SADRA and Deep Offshore Technology PJS are “agents or affiliates” of the IRGC for purposes of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA). Accordingly, any foreign financial institution knowingly conducting significant transactions with or on behalf of SADRA or Deep Offshore Technology PJS faces potential loss of its correspondent account access to the United States.

IRISL Designations

Treasury is also designating today two IRISL front companies based in Malta: Modality Limited and Malship Shipping Agency Ltd. Both companies are owned by IRISL executive Mansour Eslami, who was designated in October 2010 for his role as director of an IRISL subsidiary, IRISL (Malta) Ltd., and for his co-management of several IRISL-affiliated holding companies.

Two IRISL employees were also designated today including a senior IRISL legal advisor, Seyed Alaeddin Sadat Rasool, and Ali Ezati, IRISL’s Strategic Planning and Public Affairs Manager.

IRISL was designated by Treasury pursuant to E.O. 13382 in September 2008 for its provision of logistical services to Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL), the arm of the Iranian military that oversees its ballistic missile program.

Identifying Information

1. EZATI, Ali (a.k.a. EZZATI, Ali); DOB 5 Jun 1963; Passport Z19579335 (Iran) (individual) [NPWMD]

2. RASOOL, Seyed Alaeddin Sadat; DOB 23 Jul 1965 (individual) [NPWMD]

3. DEEP OFFSHORE TECHNOLOGY COMPANY PJS, 1st Floor, Sadra Building, No. 3, Shafagh Street, Shahid Dadman Boulevard, Paknejad Boulevard, 7th Phase, Shahrake-E-Quds, Tehran, Iran [IRGC] [NPWMD]

4. IRAN MARINE INDUSTRIAL COMPANY, SADRA (a.k.a. IRAN MARINE INDUSTRIAL COMPANY SSA; a.k.a. IRAN SADRA; a.k.a. IRAN SHIP BUILDING CO.; a.k.a. SADRA; a.k.a. SHERKATE SANATI DARYAI IRAN), 3rd Floor Aftab Building, No. 3 Shafagh Street, Dadman Blvd, Phase 7, Shahrak Ghods, P.O. Box 14665-495, Tehran, Iran; Office E-43 Torre E- Piso 4, Centrao Commercial Lido Av., Francisco de Miranda, Caracas, Venezuela; Website http://www.sadra.ir [IRGC] [NPWMD]

5. MALSHIP SHIPPING AGENCY LTD., 143/1 Tower Road, Sliema, Malta; Commercial Registry Number C43447 (Malta) [NPWMD]

6. MODALITY LIMITED, 2, Liza, Fl. 5, Triq Il-Prekursur, Madliena, Swieqi, Malta; Commercial Registry Number C49549 (Malta) [NPWMD]”

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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 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 C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.


Written Testimony of Under Secretary for Terrorism and Financial Intelligence David Cohen before the House Committee on Foreign Affairs

October 14, 2011

U.S. Department of the Treasury on October 14, 2011 released the following:

“Chairman Ros-Lehtinen, Ranking Member Berman, and distinguished members of the Committee: Thank you for the opportunity to appear before you today to discuss the Treasury Department’s efforts to implement and enforce Iran and Syria sanctions.

The focus of my testimony today will be the progress we are making in our financial strategies to increase pressure on the Iranian and the Syrian regimes. But first, I would like to say a few words about this week’s revelation that we disrupted an Iran Qods Force plot to assassinate the Saudi Ambassador here in Washington.

This is a dramatic reminder that the urgent and serious threat we face from Iran is not limited to Iran’s nuclear ambitions. We have been working for several years to address the full spectrum of Iranian illicit conduct, including nuclear and missile proliferation, human rights abuses, misuse of the international financial system and support for terrorist groups worldwide.

This week is no different. On Tuesday, Treasury imposed financial sanctions against five individuals, including the Commander of the Qods Force and three other senior Qods Force officers connected to the assassination plot. In taking this action, Treasury exposed the Iranian government’s involvement in the plot through the Qods Force, Iran’s primary arm for exporting terror.

And Wednesday, we took another action targeting Qods Force involvement in terrorist activities, this time by imposing sanctions on Mahan Air – Iran’s second largest airline – which was secretly ferrying operatives, weapons and funds on its flights for the Qods Force.

Actions like these, along with a raft of additional sanctions we have imposed on Iran over the past several months and years, have put increasing financial pressure on Iran in recent years.

CISADA has markedly amplified this effect. As we have explained to banks and governments in nearly 50 countries around the world, CISADA offers a clear choice: a foreign bank can have access to the largest and most important financial sector in the world – the United States – or it can do business with sanctioned Iranian banks, but it cannot do both. For the overwhelming majority of foreign banks, the choice has been a simple one. Those with potentially sanctionable relationships quickly elected to stop that business. And where we learn of potentially sanctionable activity under CISADA, we have actively investigated it.

Our efforts are paying off. Iran is now facing unprecedented levels of financial and commercial isolation. The number and quality of foreign banks willing to transact with designated Iranian financial institutions has dropped precipitously over the last year. Iran’s shrinking access to financial services and trade finance has made it extremely difficult for Iran to pay for imports and receive payment for exports. Iran’s Central Bank has been unable to halt the steady erosion in the value of its currency. And Iran has been increasingly unable to attract foreign investment, especially in its oil fields, leading to a projected loss of $14 billion a year in oil revenues through 2016.

Our efforts in Syria are also yielding results. Since the uprising in Syria began in March, President Obama has issued three new Executive Orders to establish sanction programs that have systematically escalated the financial pressure on the Asad regime. These U.S. sanctions – which target human rights abusers, block the assets of the Government of Syria, impose a import ban on Syrian petroleum products, and prohibit new investment in Syria – are intended to pressure Asad to relinquish power. Our efforts have been echoed by our European partners, who have established an embargo on Syrian oil and imposed financial sanctions targeting officials responsible for Syrian repression.

Echoing action that we have taken, just this morning the EU announced sanctions on the Commercial Bank of Syria, by far the largest bank in Syria, and its key link to the international financial system.

As a result of these sanctions, the Asad regime is struggling to find buyers for its oil, to access foreign currency, and to maintain economic stability. The IMF has revised its projections for the Syrian economy this year — from three percent growth to a two percent contraction – and predicts increasing pressure on Syria’s foreign currency reserves and ability to finance imports.

We are making progress, but there is still much to be done to prevent Iran and Syria from evading sanctions already in place and to take new steps to increase the pressure on these regimes. In the case of Iran, we continue to focus on the Central Bank of Iran (“the CBI”). Although U.S. financial institutions are already generally prohibited from doing business with any bank in Iran – including the CBI – further U.S. action against the CBI, if it attained multilateral support, could further isolate the CBI, with a potentially powerful impact on Iran. I can assure the Committee, as Secretary Geithner said in his letter of August 29, “All options to increase the financial pressure on Iran are on the table, including the possibility of imposing additional sanctions against the CBI.” We will also continue to work with governments in Europe, the Gulf, and elsewhere to impose financial measures that will ratchet up the pressure on Asad to step down.

If the Iranian and Syrian regimes continue to choose the path of defiance, we will continue to develop new and innovative ways to impose additional costs on them. I look forward to continuing our work with Congress to advance our national interests.”

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.


Oral Testimony by Under Secretary for Terrorism and Financial Intelligence David S. Cohen before the Senate Banking Committee

October 13, 2011

U.S. Department of the Treasury on October 13, 2011 released the following:

“As Prepared for Delivery

Chairman Johnson, Ranking Member Shelby, and distinguished members of the Committee: Thank you for the opportunity to appear here today to discuss the Treasury Department’s contribution to the Obama Administration’s integrated strategy to address the threat posed by Iran’s nuclear program and its support for terrorism.

The focus of my testimony today will be the progress we are making in our financial strategy to pressure Iran, and, in particular, the steps we are taking to implement the financial provisions of CISADA.

But first, I would like to say a few words about this week’s revelation that we disrupted an Iran Qods Force plot to assassinate the Saudi Ambassador here in Washington.

This is a dramatic reminder that the urgent and serious threat we face from Iran is not limited to Iran’s nuclear ambitions. We have been working for several years to address the full spectrum of Iranian illicit conduct, including nuclear and missile proliferation, human rights abuses, misuse of the international financial system and support for terrorist groups worldwide.

This week is no different. On Tuesday, Treasury imposed financial sanctions against five individuals, including the Commander of the Qods Force and three other senior Qods Force officers connected to the assassination plot. In taking this action, Treasury exposed the Iranian government’s involvement in the plot through the Qods Force, Iran’s primary arm for exporting terror.

And just yesterday, we took another action targeting Qods Force involvement in terrorist activities, this time by imposing sanctions on Mahan Air – Iran’s second largest airline – which was secretly ferrying operatives, weapons and funds on its flights for the Qods Force.

This week’s actions follow on a series of recent steps taken by the Treasury Department to expose Iranian illicit behavior and ratchet up the pressure on Tehran. In the last few months, we have imposed sanctions on –

  • Tidewater, a major Iranian port operator owned by the IRGC;
  • Iran Air, Iran’s national airline, for supporting the IRGC;
  • an al Qa’ida network operating in Iran under an agreement with the Iranian government;
  • and individuals and entities involved in human rights abuses, both within Iran and supporting the Syrian government’s repression of the Syrian people.

Actions like these – along with international sanctions — have put increasing financial pressure on Iran, and CISADA has markedly amplified this effect. CISADA has helped us deepen and broaden Iran’s isolation from the international financial system. Since the President signed CISADA into law last July, my colleagues in the Treasury Department and I have worked aggressively to implement it. We have met with foreign banks, regulators and government officials in nearly 50 countries. We explain to banks and governments worldwide that CISADA offers a clear choice: a foreign bank can have access to the largest and most important financial sector in the world – the United States – or it can do business with sanctioned Iranian banks, but it cannot do both.

For the overwhelming majority of foreign banks, the choice has been a simple one. Those with potentially sanctionable relationships quickly elected to stop that business. And where we learn of potentially sanctionable activity under CISADA, we have actively investigated it, engaging in particular with foreign bank’s regulator and home government.

Our efforts are paying off. Iran is now facing unprecedented levels of financial and commercial isolation. The number and quality of foreign banks willing to transact with designated Iranian financial institutions has dropped precipitously over the last year. Iran’s shrinking access to financial services and trade finance has made it extremely difficult for Iran to pay for imports and receive payment for exports. Iran’s Central Bank has been unable to halt the steady erosion in the value of its currency.

And Iran has been increasingly unable to attract foreign investment, especially in its oil fields, leading to a projected loss of $14 billion a year in oil revenues through 2016.

We are making progress, but there is still much to be done to prevent Iran from evading sanctions already in place and to apply sufficient additional pressure on Iran. In this regard, we continue to focus on the Central Bank of Iran (“the CBI”). Although U.S. financial institutions are already generally prohibited from doing business with any bank in Iran – including the CBI – further U.S. action against the CBI, if it attained multilateral support, could further isolate the CBI, with a potentially powerful impact on Iran. I can assure the Committee, as Secretary Geithner said in his letter of August 29, “All options to increase the financial pressure on Iran are on the table, including the possibility of imposing additional sanctions against the CBI.”

If Iran continues to choose its path of defiance, we will continue to develop new and innovative ways to impose additional costs on Iran. I look forward to continuing our work with Congress to advance our national interests.”

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.