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:

OFAC Litigation – SDN List Removal

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OFAC SDN Removal Attorneys

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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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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.