Iran’s President Ties Recent Drop in Currency to U.S.-Led Sanctions

October 3, 2012

The New York Times on October 2, 2012 released the following:

“By THOMAS ERDBRINK

TEHRAN — Iran’s president admitted Tuesday that the American-led economic sanctions on the country were partly to blame for a breathtaking 40 percent fall in value of the Iranian currency, the rial, over the past week. He pleaded with Iranians not to exchange their money for dollars and other foreign currencies.

Speaking during a news conference broadcast live by several domestic and international Iranian news channels, the president, Mahmoud Ahmadinejad, said Iran was facing a “psychological war” waged by the United States and aided by what he described as internal enemies.

He said the currency’s fall was caused in part by the sanctions imposed by the West over Iran’s disputed nuclear program, which have prevented it from selling oil and transferring money. He also blamed a domestic band of “22 people in three separate circles” who with “one phone call” could manipulate foreign exchange trades in Iran.

One Web site, Mashregh News, reported Tuesday that Mr. Ahmadinejad had ordered the arrests of those “disturbing the currency market.”

The fall in the currency’s value has presented Iran with enormous economic risks, including the possibility of starting a severe bout of inflation, which is already high. A rising sense of economic crisis in Iran could also pose political challenges for the country’s leaders.

Mr. Ahmadinejad’s address was aimed at the teachers, bus drivers, businessmen and others who have been frantically converting their savings into dollars and euros at the dozens of unofficial currency-exchange shops in the center of Tehran.

“I ask you, dear people, do not change your money into foreign currency,” Mr. Ahmadinejad said, emphasizing that such moves would only help the “enemy.”

But a fresh day of currency fluctuations played out on Tuesday, with the rial falling, then strengthening before sinking again, to settle around its Monday record low of roughly 37,000 to the dollar. The rate had been 24,600 rials per dollar as of last Monday.

Addressing the mixed emotions expressed by many Iranians, who are confused over whether to blame economic mismanagement by the government or the Western sanctions, Mr. Ahmadinejad accused the United States and “internal enemies.”

He described the United States government as plotting to make Iranians miserable, emphasizing that the sanctions were hurting normal people instead of Iran’s leaders. “They are telling you lies, their pressures are on the people, not on the government,” he said.

Foreign exchange supplies in the country are sufficient to quench demand, he said, and he lauded the central bank, which he said had managed to “find ways” around the obstacles.

“The enemies are trying to blame the economic problems on the government. No. Never. There is no economic reason for these erratic ups and downs,” Mr. Ahmadinejad said. “I have no doubt that we will return to normal conditions.”

But he did not offer any specific solution to the crisis, and the rial’s value weakened after he spoke. The reaction prompted one person who exchanges currency to predict that the rial would continue to lose value against the dollar and other currencies.

Mr. Ahmadinejad said the economic pressures on Iran caused by the sanctions would never force it to compromise on the country’s uranium enrichment program, which Iranian leaders say is purely peaceful but the West suspects is a cloak for developing nuclear weapons capability. But the president repeated an earlier Iranian offer to stop enriching uranium to 20 percent purity, if world powers would be willing to provide Iran with that grade of nuclear fuel.

“We have announced that if they give us the fuel, we will stop production,” Mr. Ahmadinejad said. “But so far no one is prepared to do so.”

Also on Tuesday an Iranian lawmaker threatened that Iran would enrich uranium to 60 percent purity — much closer to bomb-grade material, if talks with world powers failed.

The lawmaker, Mansour Haghighatpour, deputy head of the foreign policy and national security committee in Parliament, said Iran needed the higher enriched fuel for still-to-be-designed nuclear submarines and ships, according to Press TV, Iran state television’s English language news channel.”

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Douglas McNabb – McNabb Associates, P.C.’s
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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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HSBC suspected of drug cartel links

August 27, 2012

The Irish Times on August 27, 2012 released the following:

“US PROSECUTORS investigating the movement of money by global banks suspect HSBC of laundering money for Mexican drug cartels and transferring money through its US subsidiary for sanctioned nations, including Iran, Sudan and North Korea.

The weight of the accusations could force HSBC, which has set aside $700 million (€560 million) to cover the cost of potential fines, to pay at least $1 billion to settle the inquiry, said authorities with knowledge of the investigation. This would make it the largest such settlement in history.

It comes as UniCredit, Italy’s biggest bank, said its HypoVereinsbank unit was being investigated by US authorities over possible violation of economic sanctions.

HypoVereinsbank “has been co-operating with investigations by the New York county district attorney’s office, the US department of justice and the US treasury department’s office of foreign assets control involving US-sanctioned persons and companies”, the Italian bank said in a statement yesterday.

The money-laundering accusations against HSBC so far are more extensive than the potential violation of US sanctions that is the focus of the investigations against other foreign banks, including Deutsche Bank and Commerzbank of Germany, BNP Paribas and Crédit Agricole of France, and Royal Bank of Scotland, said the law enforcement authorities, who requested anonymity because the investigations are continuing.

“This case is not about HSBC complicity in money laundering,” a spokesman for HSBC said in a statement on Friday. “Rather, it’s about lax compliance standards that fell short of regulators’ expectations and our expectations, and we are absolutely committed to remedying what went wrong and learning from it.”

The other banks either declined to comment or did not respond to requests for comment.

Anxious to resolve the investigation, HSBC reached out to federal prosecutors in July in hopes of securing a settlement by September, according to the law enforcement officials.

But a settlement in the next couple of weeks is highly unlikely, the officials said. – (New York Times service/Bloomberg)”

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Douglas McNabb – McNabb Associates, P.C.’s
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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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Republicans Block Iran Sanctions Vote

May 18, 2012

The New York Times on May 18, 2012 released the following:

“By REUTERS

Senate Republicans blocked legislation for new economic sanctions on Iran’s oil sector on Thursday, saying they needed more time to study the bill, a surprise move that drew anger from Democrats who wanted approval ahead of nuclear talks next week. Senators from both parties said they still expected that the sanctions would pass, although the timeline was not immediately clear. The sanctions are meant to shut down any financial deals with Iran’s state oil and tanker enterprises, stripping Tehran of oil revenues. The revenues support Iran’s nuclear program, which the United States says is a cover for developing the capability to build atomic bombs, while Iran says it is for civilian purposes.”

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

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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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International criminal defense questions, but want to be anonymous?

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The Cybersecurity Market And Dangers Of U.S. Export Law

May 1, 2012

Forbes on April 30, 2012 released the following:

By Eric Savitz, Forbes Staff

Guest post written By Andrew Bigart

“This article examines the export controls applicable to the field of cybersecurity, an increasingly global industry in which U.S. companies sell their products and services to multinational companies, U.S. agencies with overseas operations, and even foreign governments, when permitted. The cybersecurity market – both public and private – hit $60 billion in 2011 and is expected to increase steadily over the next several years. Indeed, cybersecurity is one of the few defense “growth” areas to buck recent U.S. budget cuts.

As U.S. companies continue to expand in the market, however, so too does the risk of non-compliance with the confusing web of U.S. laws and regulations that govern export-related activities. U.S. law places the burden of complying with export controls and economic sanctions squarely on U.S. companies and their officers and employees. The cybersecurity industry is no exception, and may be particularly vulnerable to government scrutiny given the strategic need to protect U.S. technological advantages, critical infrastructure, and access to confidential information. In this regard, violating U.S. export laws can result in criminal law enforcement actions, jail time, and significant fines and penalties, including debarment from federal contracting.

U.S. Export Controls

The U.S. government maintains a complex set of regulations that govern the export of goods – including technology, software, and technical data – to foreign countries and specified foreign entities and individuals.

The State Department’s Directorate of Defense Trade Controls (DDTC) regulates the export of defense articles, related technical data, and defense services listed on the United States Munitions List (USML) through the International Traffic in Arms Regulations (ITAR). All manufacturers, exporters, and brokers of defense articles, related technical data and defense services are required to register with DDTC. Registration with DDTC is a prerequisite to applying for export licenses.

The Department of Commerce’s Bureau of Industry and Security (BIS) regulates anything that is not listed on the USML, including the export of commercial and dual-use commodities, software, and technology through the Export Administration Regulations (EAR). Both DDTC and BIS regulate exports depending on an item’s technical characteristics, destination, end-user, and end-use. In this regard, cybersecurity products and services present a challenge because the exports may contain a mixture of different software, encryption functions, and controlled technical information.

Finally, although not the focus of this article, it’s import to note that the Department of Treasury’s Office of Foreign Assets Control (OFAC) enforces trade embargoes and economic sanctions against specific countries (Cuba, Iran, North Korea – you get the picture) and individuals and entities (terrorists, narcotics traffickers and other bad guys). OFAC publishes the names of these ne’er-do-wells in the “Specially Designated Nationals” or “SDN” list. (BIS also maintains several lists of prohibited persons). Together, the Commerce and State export controls and OFAC sanctions programs are designed to protect U.S. foreign policy interests and to prevent U.S. persons from doing business with the wrong types of customers.

Classifying Cybersecurity Products and Services for Export Purposes

Whether an export license or other authorization is required for the export of a cybersecurity product is a fact-specific determination that includes a review of the items or services being exported, the destination, end-user and end-use. Given the complexity in classifying cybersecurity-related items, many companies request commodity jurisdiction determinations from the export agencies for guidance on whether their products are properly classified under the DDTC or BIS frameworks. These determinations, which are published, in part, by DDTC and BIS, highlight the breadth of USML and EAR classifications that potentially cover cybersecurity products and software. For example, DDTC has advised that a company’s “Customizable USB thumb drive that conducts targeted searches of digital assets for critical files” is classified under the USML section XI, which covers military electronics, as are certain military-grade GPS and cryptography products.

On the other hand, data manipulation software that uses Security Socket Layer (SSL) encryption usually qualifies for BIS’s “Mass Market Encryption” exception for items classified under Export Control Classification Numbers 5A992 and 5D992. This exception allows certain “publicly available” software to be exported to most countries without a license if the exporter registers with BIS by obtaining an Encryption Registration Number.

Moreover, both DDTC and BIS regulations define an export as including the disclosure (orally or visually) of technical information or software to a foreign person. Thus, a “deemed export” takes place when technology or software is released to foreign a person or national for visual inspection (such as reading technical specifications, plans, blueprints, etc.); when technology is exchanged orally with a foreign person or national; or when technology is made available by practice or application to a foreign person or nationals under the guidance of persons with knowledge of the technology. Depending on the nature of the technology and the country to which the technology is disclosed, releasing technology to a foreign person or national may require an export license (or in the case of ITAR possibly a Technical Assistance Agreement, depending on the individual circumstances).

Why Should The Cybersecurity Industry Care?

As the importance of cybersecurity has grown from a national defense perspective, so too has the U.S. government’s focus on regulating the export of sensitive technology. A number of recent U.S. government enforcement actions involve U.S. persons selling software, encryption products, and other cybersecurity related information abroad:

  • In 2010, a resident of China was sentenced by a federal court to serve 96 months in prison for his efforts to obtain sensitive encryption, communications, and global positioning system equipment without a DDTC license.
  • In 2009, a U.S. national working for Technical Integration Group was sentenced to six years in prison and paid $1.1 million for exporting mobile telecommunications equipment containing encryption properties to Iraq, in violation of the then U.S. embargo on Iraq.
  • In 2008, two companies paid administrative penalties to settle BIS allegations that the companies exported U.S.-origin engineering software to Iran and to companies on the BIS Entity List without the required licenses.
  • In 2002, Neopoint Inc. paid a $95,000 civil penalty to settle charges that it unlawfully exported 128-bit encryption software to South Korea.

The consequences for non-compliance with U.S. laws overseas are severe and can include large monetary fines per violation for businesses, and similar monetary fines and imprisonment for individuals. On top of that, in cases of significant violations, the consequences can include a denial of future export privileges and federal contract debarment, which is particular onerous for cybersecurity companies dependent primarily on business from U.S. government contracts.

What Can My Company Do To Minimize Risk When Selling Abroad?

The first step in minimizing export-related risk is to understand the nature of your business and potential customers, including the who, what, and where of every export transaction. The U.S. government expects companies that export to inform themselves of the facts of any export transaction and exercise reasonable care in complying with applicable U.S. export requirements. This process requires companies to determine the appropriate export classifications for their products and services. If any of your products or services falls under the USML, then you must register with DDTC as a manufacturer, exporter, or brokerer.

The next step is to develop a compliance plan that is tailored to your company’s specific export needs. A compliance plan should address, at a minimum, the following:

  • Overview of applicable laws;
  • A list of prohibited activities and employee responsibilities;
  • Regular compliance training for employees;
  • Required checking of all business partners and customers against OFAC’s SDN list on a transactional basis;
  • Rigorous internal financial and audit controls to monitor export and FCPA compliance; and
  • Required due diligence on all agents or independent contractors and required written contracts with export, economic sanctions, and FCPA prohibitions and certifications.

Finally, under U.S. law, exporters that become aware of – or should be aware of – “red flags” are required to resolve them before proceeding with a transaction. Monitoring the activities of your business partners overseas is particularly important because the conscious avoidance of knowledge of wrong doing is not a defense. Typical red flags include:

  • Transactions with incomplete information regarding end users, country of origin or destination;
  • Exportation of products that do not not fit the buyer’s line of business;
  • Unusual contract terms, payments in cash, or requests for high commissions;
  • Direct or indirect payments to government officials or their families or payments to persons outside the normal scope of a transaction;
  • Payment for travel, lodging, or business expenses or extravagant gifts or entertaining of government officials or their families; and
  • Consultants who are connected with a foreign government or political party.

What if a Potential Violation Arises?

Unfortunately, for some companies the legal risks of doing business abroad are not apparent until something goes wrong. If you discover questionable business practices regarding your export-related activities, stop the conduct in question immediately and report the activities to your company’s compliance officer. If your company finds itself in such a position, consider the option of a voluntary disclosure. Each of the agencies discussed above – Commerce, State, and OFAC – maintain procedures that encourage companies to self-report violations under certain circumstances. Although these programs do not allow companies to evade liability completely, they do offer reduced penalties and other incentives.

Conclusion

There is no doubt that the export market for cybersecurity products and services remains an attractive and growing market for U.S. exporters. Before taking the leap overseas, however, take the time to review and understand your company’s responsibilities under U.S. export control and economic sanctions. An ounce of prevention in this regard goes a long way in keeping your business profitable and out of trouble.”

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

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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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International criminal questions, but want to be anonymous?

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Obama announces sanctions for tech used in human rights abuses in Iran and Syria

April 23, 2012

Washington Post on April 23, 2012 released the following:

“President Obama issued an executive order Monday that allows U.S. officials for the first time to impose sanctions against foreign nationals found to have used new technologies, including cellphone tracking and Internet monitoring, to help carry out grave human rights abuses.

Social media and cellphone technology have been widely credited with helping democracy advocates organize against autocratic governments and better expose rights violations, most notably over the past year and a half in the Middle East and North Africa.

But authoritarian governments, particularly in Syria and Iran, have shown that their security services can also harness technology to help crack down on dissent — by conducting surveillance, blocking access to the Internet or tracking the movements of opposition figures.

Obama’s executive order, which he announced during a Monday speech at the U.S. Holocaust Memorial Museum, is an acknowledgment of those dangers and of the need to adapt American national security policy to a world being remade rapidly by technology, according to senior administration officials familiar with the plans. Although the order is designed to target companies and individuals assisting the governments of Iran and Syria, they said, future executive orders could name others aiding other countries through technology in crackdowns on dissent.

Under the order, the administration announced new sanctions, including a U.S. visa ban and financial restrictions, against a range of Syrian and Iranian agencies and individuals.

In Syria, the sanctions target the Syrian General Intelligence Directorate, the Syriatel phone company and Ali Mamluk, the director of Syria’s general intelligence services. In Iran, the Islamic Revolutionary Guard, the Iranian Ministry of Intelligence and Security, the Law Enforcement Forces of the Islamic Republic of Iran, and Datak Telecom will be subject to the new sanctions.

Speaking in solemn tones, Obama described the challenges of fulfilling the “never again” pledge in the 21st century, telling the audience, “We must tell our children about a crime unique in human history: the one and only Holocaust. … We must tell them how they died, but also how they lived.”

But, he added, “remembrance without action changes nothing.”

“In that sense, ‘never again’ is a challenge to us all,” he said.

Obama’s speech at the most visible U.S. symbol of Holocaust remembrance comes at a time when his policy toward Syria, where a government crackdown has killed thousands of civilians, is under sharp criticism from his Republican rivals for the presidency.

To demonstrate the priority he places on genocide prevention, Obama used the roughly 20-minute address to reveal that he has asked for the first-ever National Intelligence Estimate — the consensus view of all U.S. intelligence agencies — appraising the potential for mass killings in countries around the world and their implication for U.S. interests.

The president also announced a set of U.S. development “challenge” grants designed to encourage technology companies to develop new ways to help residents in countries vulnerable to mass killings better detect and quickly alert others to impending dangers. And he will unveil a high-level government panel to serve as a clearinghouse for real-time intelligence, policymaking and other issues related to mass killing.

“This unprecedented direction from the president, and the development of a comprehensive strategy, sends a clear message that we are committed to combating atrocities, an old threat that regularly takes grim and modern new forms,” said Samantha Power, the National Security Council’s senior director for multilateral affairs and human rights, who will serve as chairman of the Atrocities Prevention Board. The panel’s creation was announced in August.

Last year, Obama cited an imminent threat to Libya’s civilians to explain his decision to intervene militarily against longtime leader Moammar Gaddafi.

“To brush aside America’s responsibility as a leader and ­— more profoundly — our responsibilities to our fellow human beings under such circumstances would have been a betrayal of who we are,” he said at the time.

In October, Obama dispatched 100 U.S. troops to Uganda and its neighbors to help the region’s governments hunt down Joseph Kony, the fanatical head of the Lord’s Resistance Army, notorious for its campaign of civilian slaughter and child kidnapping.

But Republicans and some human rights advocates have derided Obama’s policy in Syria as weak and pressed him to do more to stop the killings there.

Last week, echoing Obama’s own remarks on Libya delivered a year earlier, Sen. John McCain (R-Ariz.) said that “for the United States to sit by and watch this wanton massacre is a betrayal of everything that we stand for and believe in.”

Obama has called for the removal of Syrian President Bashar al-Assad and imposed a set of economic sanctions against his government. But Assad has ignored international pressure and kept up a brutal crackdown that human rights groups estimate has killed more than 11,000 people.

In some cases, Syrian security forces are using technology to track down the opposition movement’s leaders. Syrian officials may also have tracked satellite phones and computer addresses to locate a group of foreign journalists in February who were covering the siege of the city of Homs.

Two journalists were killed in an attack on a building where they were seeking shelter from government bombardment, among them Marie Colvin, an American working for the Sunday Times of London.

In his new executive order, Obama states that “the same GPS, satellite communications, mobile phone, and Internet technology employed by democracy activists across the Middle East and North Africa is being used against them by the regimes in Syria and Iran.”

The new steps are designed primarily to target companies explicitly aiding authoritarian governments with new technology that assists in civilian repression.

But senior administration officials say the measures should prompt all companies to think harder about how the technology they are providing to other countries might be employed and to take steps to ensure that it is not used in harmful ways.

“These technologies should be in place to empower citizens, not oppress them,” Obama said.

Obama’s visit to the memorial followed by a few days the official Holocaust Remembrance Day, and he used the first part of his speech to discuss the mass killing of Jews in Europe.

He recalled his visit to Buchenwald in June 2009, touring the former Nazi concentration camp on a still afternoon with Nobel Peace laureate and Holocaust survivor Elie Wiesel. Wiesel also accompanied him Monday at the museum, and in his remarks, Obama thanked him and all Holocaust survivors for “not giving up.”

“If you can believe,” he said, “then we can believe.”

Obama used the second part of his remarks to discuss the legacy of Rwanda and his efforts in Libya, Sudan and central Africa, Ivory Coast and other places where mass killings or the threat of them have drawn U.S. attention.

The new Atrocities Prevention Board is intended to elevate the issue further in his administration, officials say. It will comprise senior representatives from across the administration with the goal of helping “the U.S. government identify and address atrocity threats and oversee institutional changes that will make us more nimble and effective.”

The board will hold its first session Monday afternoon and plans to meet with as many as 200 representatives of the nongovernmental organizations, university chapters of anti-genocide groups and others involved in the issue.

“This is not an afterthought, this is not a sidelight of our foreign policy,” Obama said.“We’re going to institutionalize the focus on this issue.””

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


U.S. Treasury Designates Lebanese Canadian Bank Sal as a “Primary Money Laundering Concern”

February 10, 2011

The U.S. Treasury Department says the Lebanese Canadian Bank SAL together with its subsidiaries (LCB) has laundered hundreds of millions of dollars for a drug trafficking group with ties to Hezbollah, which Washington considers a terrorist organization.

The Treasury Department and the Drug Enforcement Administration say Lebanese Canadian Bank SAL has been designated a “primary money laundering concern” for allegedly helping launder up to $200 million a month for a Lebanese-based drug smuggling group. The agencies say alleged drug kingpin Ayman Joumaa runs the ring.

LCB has been designated under Section 311 of the USA Patriot Act. Section 311 actions are distinct from designations brought by Treasury’s Office of Foreign Assets Control (OFAC), which are applied more broadly, prohibit transactions and trigger asset freezing obligations. For an overview of Section 311 of the USA Patriot Act, please click here.

Allegedly, Joumaa and his Lebanon-based drug trafficking and money laundering network, along with several other individuals, have used LCB to launder narcotics proceeds as part of this international money laundering network. On January 26, Treasury designated Joumaa along with nine individuals and 19 entities in his network as Specially Designated Narcotics Traffickers pursuant to the Foreign Narcotics Kingpin Designation Act (Kingpin Act). Following today’s action by the Treasury, more individuals may soon face an OFAC SDN designation.

The Treasury’s Financial Crimes Enforcement Network (FinCEN) also today filed a Notice of Proposed Rule Making (NPRM), in which it proposes prohibiting U.S. financial institutions from opening or maintaining correspondent or payable-through accounts for LCB.

For a complete reading of the Treasury press release, please click here.

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 mcnabb@mcnabbassociates.com or at one of the offices listed above.

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Sanctions Placed on Belarus Leader

January 31, 2011

Speculation is confirmed, as the European Union and United States place sanctions on Belarus President Alexander Lukashenko and his inner circle on Monday as punishment for a post-election crackdown on the opposition. The sanctions include a travel ban on Lukashenko and his allies, in addition to financial sanctions.

Lukashenko won a disputed election in December, resulting in mass protests with more than 600 people detained, including seven of the candidates.

Sanctions against the Belarusian leader were originally imposed in 2006 after the last presidential election but the travel ban was suspended two years later in an attempt to encourage reforms.

Regarding the current sanctions, the EU stopped short of imposing wider economic sanctions against the Belarus state, as called for by Sweden and Poland, because others did not want to make the people of Belarus pay.

In addition to travel sanctions, the US has also revoked licences that had temporarily authorized Americans to engage in transactions with two subsidiaries of the largest state-owned petroleum and chemical conglomerate in Belarus.

Just last week, Congress was addressing the issue of how to handle the Belarusian government. Congress was urged to revoke general licenses that had been issued, increase the number of those on the travel ban, and impose further financial sanctions against specific individuals and entities. To view the Congressional testimony before the Subcommittee on European Affairs of the Senate Foreign Relations Committee, click here.

OFAC will be the federal agency responsible for revoking licenses previously issued, in addition to imposing financial sanctions and designating Belarusian individuals and entities on the SDN List.

Douglas McNabb and other members of the firm practice and write extensively on matters involving Federal Criminal Defense, Interpol Litigation, International Extradition and OFAC Litigation.

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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