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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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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“U.S. Imposes Sanctions on Those Aiding Iran”

May 10, 2013

The New York Times on May 9, 2013 released the following:

By RICK GLADSTONE

“The United States on Thursday expanded its roster of those violating Iran sanctions, blacklisting four Iranian companies and one individual suspected of helping the country enrich nuclear fuel. It also singled out two other companies, including a Venezuelan-Iranian bank, accused of helping Iran evade other Western-imposed prohibitions on oil sales and financial dealings.

The penalties announced by the Treasury and State Departments came a day after the Senate introduced legislation that could effectively deny the Iran government access to an estimated $100 billion worth of its own money parked in overseas banks, a step that proponents said could significantly damage Iran’s financial stability.

That legislation, known as the Iran Sanctions Loophole Elimination Act, is expected to be integrated into a broader House measure introduced in February.

The actions on Thursday appeared to signal an accelerated American effort to squeeze Iran economically over the lack of progress in negotiations on the disputed Iranian nuclear program, which Iran says is peaceful but the West has called a guise to achieve the ability to make atomic bombs.

The latest round of negotiations last month ended inconclusively, and Western critics of Iran have accused it of stalling for time while it continues to enrich uranium.

“With Iran’s nuclear program marching steadily forward, we need to work as quickly as possible to eliminate any sources of funding for the regime,” the chairman of the House Foreign Affairs Committee, Representative Ed Royce, a California Republican, said in a statement issued jointly with the ranking Democrat, Representative Eliot Engel of New York.

They said the committee would hold a hearing Wednesday on Iran’s nuclear activities.

Any assets that blacklisted companies or individuals may have under American jurisdiction can be frozen, and they are prohibited from doing business with American citizens or businesses. Other individuals or business that engage with those under sanctions are themselves subject to penalties.

Iran has characterized the sanctions as illegal bullying by the United States and its allies. Some critics of the sanctions have said they are more likely to harden Iran’s resistance.

A State Department announcement said four Tehran-based businesses, identified as Aluminat, Pars Amayesh Sanaat Kish, Pishro Systems Research Company and Taghtiran Kashan Company, and an Iranian citizen from Tehran identified as Parviz Khaki, were all blacklisted for providing goods, technology and services for activities that violated United Nations Security Council sanctions on Iran’s nuclear activities.

“This action was taken in light of the ongoing concerns that the international community has with respect to Iran’s nuclear program, which Iran continues to refuse to address,” the State Department announcement said.

In what appeared to be a coordinated announcement, the Treasury Department’s Office of Foreign Assets Control, which helps administer sanctions, announced that it was punishing Sambouk Shipping FZC, based in the United Arab Emirates, for cloaking the origin of Iranian oil and selling it on the international market. The Treasury said that the company was owned by a Greek business executive, Dmitris Cambis, who was blacklisted earlier this year for ties to sanctioned Iranian companies.

In addition, the Treasury penalized the Iranian Venezuelan Bi-National Bank, based in Tehran, for engaging in financial transactions for the Export Development Bank of Iran, which has already been blacklisted.

“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,” David S. Cohen, the under secretary for terrorism and financial intelligence, said in the Treasury announcement. “As long as Iran tries to evade our sanctions, we will continue to expose their deceptive maneuvers.””

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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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“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.

————————————————————–

International criminal defense questions, but want to be anonymous?

Free Skype Tel: +1.202.470.3427, OR

Free Skype call:

           Office Locations

Email: