The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC): “Iran Designations”

June 4, 2013

The U.S. Department of the Treasury on June 4, 2013 released the following:

“OFFICE OF FOREIGN ASSETS CONTROL
Specially Designated Nationals List Update

Click here for more information about the Execution of Imam Khomeini’s Order (EIKO) International Financial Network

The following entities have been added to OFAC’s SDN List:

AMIN INVESTMENT BANK (a.k.a. AMINIB), No. 51 Ghobadiyan Street, Valiasr Street, Tehran 1968917173, Iran; Website http://www.aminib.com [IRAN].

BEHSAZ KASHANE TEHRAN CONSTRUCTION CO. (a.k.a. BEHSAZ KASHANEH CO.), No. 40, East Street Journal, North Shiraz Street, Sadra Avenue, Tehran, Iran; Website http://www.behsazco.ir [IRAN].

COMMERCIAL PARS OIL CO., 9th Floor, No. 346, Mirdamad Avenue, Tehran, Iran [IRAN].

CYLINDER SYSTEM L.T.D. (a.k.a. CILINDER SISTEM D.O.O.; a.k.a. CILINDER SISTEM D.O.O. ZA PROIZVODNJU I USLUGE), Dr. Mile Budaka 1, Slavonski Brod 35000, Croatia; 1 Mile Budaka, Slavonski Brod 35000, Croatia; Website http://www.csc-sb.hr; Registration ID 050038884 (Croatia); Tax ID No. 27694384517 (Croatia) [IRAN].

EXECUTION OF IMAM KHOMEINI’S ORDER (a.k.a. EIKO; a.k.a. SETAD; a.k.a. SETAD EJRAEI EMAM; a.k.a. SETAD-E EJRAEI-E FARMAN-E HAZRAT-E EMAM; a.k.a. SETAD-E FARMAN-EJRAEI-YE EMAM), Khaled Stamboli St., Tehran, Iran [IRAN].

GHADIR INVESTMENT COMPANY, 341 West Mirdamad Boulevard, Tehran, Iran; P.O. Box 19696, Tehran, Iran; Website http://www.ghadir-invest.com [IRAN].

GHAED BASSIR PETROCHEMICAL PRODUCTS COMPANY (a.k.a. GHAED BASSIR), No. 15, Palizvani (7th) Street, Gandhi (South) Avenue, Tehran 1517655711, Iran; Km 10 of Khomayen Road, Golpayegan, Iran; Website http://www.gbpc.net [IRAN].

GOLDEN RESOURCES TRADING COMPANY L.L.C. (a.k.a. “GRTC”), 9th Floor, Office No. 905, Khalid Al Attar Tower 1, Sheikh Zayed Road, After Crown Plaza Hotel, Al Wasl Area, Dubai, United Arab Emirates; Postal Box 34489, Dubai, United Arab Emirates; Postal Box 14358, Dubai, United Arab Emirates [IRAN].

HORMOZ OIL REFINING COMPANY, Next to the Current Bandar Abbas Refinery, Bandar Abbas City, Iran [IRAN].

IRAN & SHARGH COMPANY (a.k.a. IRAN AND EAST COMPANY; a.k.a. IRAN AND SHARGH COMPANY; a.k.a. IRANOSHARGH COMPANY; a.k.a. SHERKAT-E IRAN VA SHARGH), 827, North of Seyedkhandan Bridge, Shariati Street, P.O. Box 13185-1445, Tehran 16616, Iran; No. 41, Next to 23rd Alley, South Gandi St., Vanak Square, Tehran 15179, Iran; Website http://www.iranoshargh.com [IRAN].

IRAN & SHARGH LEASING COMPANY (a.k.a. IRAN AND EAST LEASING COMPANY; a.k.a. IRAN AND SHARGH LEASING COMPANY; a.k.a. SHERKAT-E LIZING-E IRAN VA SHARGH), 1st Floor, No. 33, Shahid Atefi Alley, Opposite Mellat Park, Vali-e-Asr Street, Tehran 1967933759, Iran; Website http://www.isleasingco.com [IRAN].

MARJAN PETROCHEMICAL COMPANY (a.k.a. MARJAN METHANOL COMPANY), Ground Floor, No. 39, Meftah/Garmsar West Alley, Shiraz (South) Street, Molla Sadra Avenue, Tehran, Iran; Post Office Box 19935-561, Tehran, Iran [IRAN].

MCS ENGINEERING (a.k.a. EFFICIENT PROVIDER SERVICES GMBH), Karlstrasse 21, Dinslaken, Nordrhein-Westfalen 46535, Germany [IRAN].

MCS INTERNATIONAL GMBH (a.k.a. MANNESMAN CYLINDER SYSTEMS; a.k.a. MCS TECHNOLOGIES GMBH), Karlstrasse 23-25, Dinslaken, Nordrhein-Westfalen 46535, Germany; Website http://www.mcs-tch.com [IRAN].

MELLAT INSURANCE COMPANY, No. 48, Haghani Street, Vanak Square, Before Jahan-Kodak Cross, Tehran 1517973913, Iran; No. 40, Shahid Haghani Express Way, Vanak Square, Tehran, Iran; No. 9, Niloofar Street, Sharabyani Avenue, Taavon Boulevard, Shahr-e-Ziba, Tehran, Iran; 72 Hillview Court, Woking, Surrey GU22 7QW, United Kingdom; No. 697 Saeeidi Alley, Crossroads College, Enghelab St., Tehran, Iran; Website http://www.mellatinsurance.com [IRAN].

MODABER (a.k.a. MODABER INVESTMENT COMPANY; a.k.a. TADBIR INDUSTRIAL HOLDING COMPANY) [IRAN].

OIL INDUSTRY INVESTMENT COMPANY (a.k.a. “O.I.I.C.”), No. 83, Sepahbod Gharani Street, Tehran, Iran; Website http://www.oiic-ir.com [IRAN].

OMID REY CIVIL & CONSTRUCTION COMPANY (a.k.a. OMID DEVELOPMENT AND CONSTRUCTION; a.k.a. OMID REY CIVIL AND CONSTRUCTION COMPANY; a.k.a. OMID REY RENOVATION AND DEVELOPMENT CO.); Website http://www.omidrey.com [IRAN].

ONE CLASS PROPERTIES (PTY) LTD. (a.k.a. ONE CLASS INCORPORATED), Cape Town, South Africa [IRAN].

ONE VISION INVESTMENTS 5 (PTY) LTD. (a.k.a. ONE VISION 5), 3rd Floor, Tygervalley Chambers, Bellville, Cape Town 7530, South Africa; Canal Walk, P.O. Box 17, Century City, Milnerton 7446, South Africa; Registration ID 2002/022757/07 (South Africa) [IRAN].

PARDIS INVESTMENT COMPANY (a.k.a. SHERKAT-E SARMAYEGOZARI-E PARDIS), Iran; Unit D4 and C4, 4th Floor, Building 29 Africa, Corner of 25th Street, Africa Boulevard, Tehran, Iran [IRAN].

PARS MCS (a.k.a. PARS MCS CO.; a.k.a. PARS MCS COMPANY), 2nd Floor, No. 4, Sasan Dead End, Afriqa Avenue, After Esfandiar, Crossroads, Tehran, Iran; No. 5 Sasan Alley, Atefi Sharghi St., Afrigha Boulevard, Tehran, Iran; Oshtorjan Industrial Zone, Zob-e Ahan Highway, Isafahan, Iran; Website http://www.parsmcs.com [IRAN].

PARS OIL CO. (a.k.a. PARS OIL; a.k.a. SHERKAT NAFT PARS SAHAMI AAM), Iran; No. 346, Pars Oil Company Building, Modarres Highway, East Mirdamad Boulevard, Tehran 1549944511, Iran; Postal Box 14155-1473, Tehran 159944511, Iran; Website http://www.parsoilco.com [IRAN].

PERSIA OIL & GAS INDUSTRY DEVELOPMENT CO. (a.k.a. PERSIA OIL AND GAS INDUSTRY DEVELOPMENT CO.; a.k.a. TOSE SANAT-E NAFT VA GAS PERSIA), 7th Floor, No. 346, Mirdamad Avenue, Tehran, Iran; Ground Floor, No. 14, Saba Street, Africa Boulevard, Tehran, Iran; Website http://www.pogidc.com [IRAN].

POLYNAR COMPANY, No. 58, St. 14, Qanbarzadeh Avenue, Resalat Highway, Tehran, Iran; Website http://www.polynar.com [IRAN].

REY INVESTMENT COMPANY, 2nd and 3rd Floors, No. 14, Saba Boulevard, After Esfandiar Crossroad, Africa Boulevard, Tehran 1918973657, Iran; Website http://www.rey-co.com [IRAN].

REY NIRU ENGINEERING COMPANY (a.k.a. REY NIROO ENGINEERING COMPANY); Website http://www.reyniroo.com [IRAN].

REYCO GMBH. (a.k.a. REYCO GMBH GERMANY), Karlstrasse 19, Dinslaken, Nordrhein-Westfalen 46535, Germany [IRAN].

RISHMAK PRODUCTIVE & EXPORTS COMPANY (a.k.a. RISHMAK COMPANY; a.k.a. RISHMAK EXPORT AND MANUFACTURING P.J.S.; a.k.a. RISHMAK PRODUCTION AND EXPORT COMPANY; a.k.a. RISHMAK PRODUCTIVE AND EXPORTS COMPANY; a.k.a. SHERKAT-E TOLID VA SADERAT-E RISHMAK), Rishmak Cross Rd., 3rd Km. of Amir Kabir Road, Shiraz 71365, Iran [IRAN].

ROYAL ARYA CO. (a.k.a. ARIA ROYAL CONSTRUCTION COMPANY), Iran [IRAN].

SADAF PETROCHEMICAL ASSALUYEH COMPANY (a.k.a. SADAF ASALUYEH CO.; a.k.a. SADAF CHEMICAL ASALUYEH COMPANY; a.k.a. SADAF PETROCHEMICAL ASSALUYEH INVESTMENT SERVICE), Assaluyeh, Iran; South Pars Special Economy/Energy Zone, Iran [IRAN].

TADBIR BROKERAGE COMPANY (a.k.a. SHERKAT-E KARGOZARI-E TADBIRGARAN-E FARDA; a.k.a. TADBIRGARAN FARDA BROKERAGE COMPANY; a.k.a. TADBIRGARAN-E FARDA BROKERAGE COMPANY; a.k.a. TADBIRGARANE FARDA MERCANTILE EXCHANGE CO.), Unit C2, 2nd Floor, Building No. 29, Corner of 25th Street, After Jahan Koudak, Cross Road Africa Street, Tehran 15179, Iran; Website http://www.tadbirbroker.com [IRAN].

TADBIR CONSTRUCTION DEVELOPMENT COMPANY (a.k.a. GORUH-E TOSE-E SAKHTEMAN-E TADBIR; a.k.a. TADBIR BUILDING EXPANSION GROUP; a.k.a. TADBIR HOUSING DEVELOPMENT GROUP), Block 1, Mehr Passage, 4th Street, Iran Zamin Boulevard, Shahrak Qods, Tehran, Iran [IRAN].

TADBIR ECONOMIC DEVELOPMENT GROUP (a.k.a. TADBIR GROUP), 16 Avenue Bucharest, Tehran, Iran [IRAN].

TADBIR ENERGY DEVELOPMENT GROUP CO., 6th Floor, Mirdamad Avenue, No. 346, Tehran, Iran; Website http://www.tadbirenergy.com [IRAN].

TADBIR INVESTMENT COMPANY, Tehran, Iran [IRAN].

TOSEE EQTESAD AYANDEHSAZAN COMPANY (a.k.a. TEACO; a.k.a. TOSEE EGHTESAD AYANDEHSAZAN COMPANY), 39 Gandhi Avenue, Tehran 1517883115, Iran [IRAN].

ZARIN RAFSANJAN CEMENT COMPANY (a.k.a. RAFSANJAN CEMENT COMPANY; a.k.a. ZARRIN RAFSANJAN CEMENT COMPANY), 2nd Floor, No. 67, North Sindokht Street, West Dr. Fatemi Avenue, Tehran 1411953943, Iran; Website http://www.zarrincement.com [IRAN].”

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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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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

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 Iranian Financial Sanctions Regulations [IFSR] Entries Added to OFAC’s SDN List on May 15, 2013

May 15, 2013

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

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

AL FIDA INTERNATIONAL GENERAL TRADING, Emirates Concord Hotel, Office Tower 16th Floor Flat 1065, P.O. Box: 28774, Dubai, United Arab Emirates [NPWMD] [IFSR].

AL HILAL EXCHANGE, P.O. Box 28774, Shop # 9 & 10 Ground Floor, Emirates Concorde Hotel, Al Maktoum Road, Deira Dubai, United Arab Emirates; Emirates Concorde Hotel & Residence, Almaktoum Street, P.O. Box 28774, Dubai, United Arab Emirates [NPWMD] [IFSR].”

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Treasury Targets Exchange House and Trading Company Linked to Iranian Attempts to Evade Sanctions

5/15/2013

Action Designates Financial Institutions Involved in Providing Foreign Currency Exchange for the Iranian Regime

WASHINGTON – The U.S. Department of the Treasury designated an exchange house and a trading company today for aiding Iranian attempts to circumvent international economic sanctions. Al Hilal Exchange and Al Fida International General Trading, which are based in the United Arab Emirates, were designated pursuant to Executive Order (E.O.) 13382 for providing financial services to previously designated Iranian banks. They have been used by Iran in an attempt to maintain access to foreign currency exchange.

“As Iran’s access to the international banking sector comes under increasing pressure, we have seen it turn increasingly to exchange houses and trading companies in its attempts to evade international sanctions and maintain its access to foreign exchange,” said Under Secretary for Terrorism and Financial Intelligence David S. Cohen. “We have warned the financial community about the risks posed by Iran’s use of exchange houses and trading companies to evade sanctions, and today’s action makes clear that we will impose sanctions against non-bank financial institutions that facilitate Iran’s illicit conduct. We will continue to work with our partners in the UAE and around the world to increase pressure on the Iranian regime as it fails to address well founded concerns about its nuclear program.”

Both Al Hilal Exchange and Al Fida International General Trading are being designated today pursuant to E.O. 13382 for their role in providing financial services to Bank Mellat, a designated Iranian bank directly involved with the Iranian nuclear program.

Al Hilal Exchange, an exchange house based in Dubai, UAE, offers services related to remittances, currency exchange and credit card services. During a three-month span in early 2012, Al Hilal Exchange provided foreign currency exchange services worth more than $55 million to Bank Mellat. Al Hilal Exchange is also being designated for providing financial services to Bank Melli, specifically currency exchange services. Treasury previously designated Bank Melli for its financial services for the Atomic Energy Association of Iran and the Iranian Ministry of Defense for Armed Forces Logistics in 2007.

The Central Bank of the UAE recently took action against Al Hilal Exchange, revoking its license on May 8, 2013 for major regulatory and anti-money laundering compliance violations. The U.S. Government welcomes this action taken by the Government of the UAE and commends the UAE for taking action to combat the risks posed to the UAE and international financial system by the illicit financial operations of this exchange house. We look forward to further opportunities to collaborate with the UAE on combating illicit finance.

Al Fida International General Trading, also located in Dubai, collaborated with Al Hilal Exchange to provide Bank Mellat with access to foreign currency. Bank Mellat transferred currency to Al Hilal Exchange through an Al Fida General Trading account in an attempt to obscure the origins of the funds.

U.S. persons are generally prohibited from engaging in any transactions with the entities designated today, and any assets of those entities subject to U.S. jurisdiction are frozen. Additionally, today’s designations under E.O. 13382 carry consequences under the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA). Foreign financial institutions that knowingly facilitate significant transactions or provide significant financial services for these sanctioned entities or individual are exposed to potential loss of access to the U.S. financial system.

Please note, Al Hilal Exchange, one of the entities being designated today, is separate and distinct from Al Hilal Bank, which is also based in the UAE. Today’s sanctions are not imposed on Al Hilal Bank.

For guidance on the risks posed by Iran’s use of exchange houses and trading companies, see the Office of Foreign Assets Control’s January 10, 2013 release on “The Use of Exchange Houses and Trading Companies to Evade U.S. Economic Sanctions Against Iran.”

Identifying Information

Name: Al Hilal Exchange

Address: P.O. Box 28774, Shop #9 & 10 Ground Floor, Emirates Concorde Hotel, Al-Maktoum Road, Deira Dubai, United Arab Emirates

Alt. Address: Emirates Concorde Hotel & Residence, Almaktoum Street, P.O. Box 28774, Dubai, United Arab Emirates

Name: Al Fida International General Trading

Address: P.O. Box: 28774, Office Tower 16th Floor Flat 1065, Emirates Concorde Hotel, Dubai, United Arab Emirates”

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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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“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.””

————————————————————–

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

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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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OFAC: “Iran Sanctions Designations; Non-Proliferation Sanctions Designations; Iran Sanctions Designations Updates”

May 9, 2013

The U.S. Department of the Treasury on May 9, 2013 released the following:

“OFFICE OF FOREIGN ASSETS CONTROL

Specially Designated Nationals Update

The following individual has been added to OFAC’s SDN List:

KHAKI, Parviz (a.k.a. “MARTIN”); DOB 26 Aug 1968; POB Tehran, Iran (individual) [NPWMD] [IFSR].

The following entities have been added to OFAC’s SDN List:

ALUMINAT (a.k.a. ALUMINAT PRODUCTION AND INDUSTRIAL COMPANY), Unit 38, 5th Floor, No. 9, Golfam Avenue, Africa Avenue, Tehran, Iran; Factory-Kilometer 13, Arak Road, Parcham Street, Arak, Iran [NPWMD] [IFSR].

IRANIAN-VENEZUELAN BI-NATIONAL BANK (a.k.a. “IVBB”), Tosee Building Ground Floor, Bokharest Street 44-46, Tehran, Iran; SWIFT/BIC IVBBIRT1; all offices worldwide [NPWMD] [IFSR].

PARS AMAYESH SANAAT KISH (a.k.a. PASK; a.k.a. VACUUM KARAN; a.k.a. VACUUM KARAN CO.; a.k.a. VACUUMKARAN), 3rd Floor, No. 6, East 2nd, North Kheradmand, Karimkhan Street, Tehran, Iran [NPWMD] [IFSR].

PISHRO SYSTEMS RESEARCH COMPANY (a.k.a. ADVANCED SYSTEMS RESEARCH COMPANY; a.k.a. ASRC; a.k.a. CENTER FOR ADVANCED SYSTEMS RESEARCH; a.k.a. CRAS; a.k.a. PISHRO COMPANY), Tehran, Iran [NPWMD] [IFSR].

SAMBOUK SHIPPING FZC, FITCO Building No. 3, Office 101, 1st Floor, P.O. Box 50044, Fujairah, United Arab Emirates; Office 1202, Crystal Plaza, PO Box 50044, Buhaira Corniche, Sharjah, United Arab Emirates [IRAN] (Linked To: CAMBIS, Dimitris).

TAGHTIRAN KASHAN COMPANY (a.k.a. TAGHTIRAN P.J.S.), Flat 2, No. 3, 2nd Street, Azad-Abadi Avenue, Tehran 14316, Iran; KM 44 Kashan-Delijan Road, P.O. Box Kashan 87135/1987, Kashan, Iran [NPWMD] [IFSR].

The following vessels have been added to OFAC’s SDN List:

ATLANTIS (5IM316) Crude Oil Tanker Tanzania flag (NITC); Vessel Registration Identification IMO 9569621 (vessel) [IRAN].

BADR (EQJU) Iran flag; Vessel Registration Identification IMO 8407345 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).

DEMOS (5IM656) Crude Oil Tanker Tanzania flag (NITC); Vessel Registration Identification IMO 9569683 (vessel) [IRAN].

INFINITY (5IM411) Crude Oil Tanker Tanzania flag (NITC); Vessel Registration Identification IMO 9569671 (vessel) [IRAN].

JUSTICE Crude Oil Tanker None Identified flag; Vessel Registration Identification IMO 9357729 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).

SKYLINE (5IM632) Crude Oil Tanker Tanzania flag (NITC); Vessel Registration Identification IMO 9569669 (vessel) [IRAN].

SUNRISE LPG Tanker None Identified flag (NITC); Vessel Registration Identification IMO 9615092 (vessel) [IRAN].

YOUNES (EQYY) Platform Supply Ship Iran flag; Vessel Registration Identification IMO 8212465 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).

The following changes have been made to OFAC’s SDN List:

ALPHA (f.k.a. ABADAN) (T2EU4) Crude/Oil Products Tanker None Identified flag; Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; Vessel Registration Identification IMO 9187629; MMSI 572469210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY). -to- SHONA (f.k.a. ABADAN; f.k.a. ALPHA) (T2EU4) Crude/Oil Products Tanker Tanzania flag; Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag None Identified; Vessel Registration Identification IMO 9187629; MMSI 572469210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).

AZALEA (f.k.a. SINA) (9HNY9) Crude Oil Tanker None Identified flag; Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; Vessel Registration Identification IMO 9357365; MMSI 249256000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY). -to- SUNEAST (f.k.a. AZALEA; f.k.a. SINA) (9HNY9) Crude Oil Tanker Seychelles flag; Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag None Identified; Vessel Registration Identification IMO 9357365; MMSI 249256000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).

DAMAVAND (9HEG9) Crude Oil Tanker Malta flag; Vessel Registration Identification IMO 9218478; MMSI 256865000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY). -to- DAMAVAND (9HEG9) Crude Oil Tanker None Identified flag; Former Vessel Flag Malta; Vessel Registration Identification IMO 9218478; MMSI 256865000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).

DARAB (9HEE9) Crude Oil Tanker Malta flag; Vessel Registration Identification IMO 9218492; MMSI 256862000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY). -to- DARAB (9HEE9) Crude Oil Tanker None Identified flag; Former Vessel Flag Malta; Vessel Registration Identification IMO 9218492; MMSI 256862000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).

DAYLAM (9HEU9) Crude Oil Tanker Malta flag; Vessel Registration Identification IMO 9218466; MMSI 256872000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY). -to- DAYLAM (9HEU9) Crude Oil Tanker None Identified flag; Former Vessel Flag Malta; Vessel Registration Identification IMO 9218466; MMSI 256872000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).

DELVAR (9HEF9) Crude Oil Tanker Malta flag; Vessel Registration Identification IMO 9218454; MMSI 256864000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY). -to- DELVAR (9HEF9) Crude Oil Tanker None Identified flag; Former Vessel Flag Malta; Vessel Registration Identification IMO 9218454; MMSI 256864000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).

DENA (9HED9) Crude Oil Tanker Malta flag; Vessel Registration Identification IMO 9218480; MMSI 256861000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY). -to- DENA (9HED9) Crude Oil Tanker None Identified flag; Former Vessel Flag Malta; Vessel Registration Identification IMO 9218480; MMSI 256861000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).

HUWAYZEH (9HEJ9) Crude Oil Tanker Malta flag; Vessel Registration Identification IMO 9212888; MMSI 256869000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY). -to- HUWAYZEH (9HEJ9) Crude Oil Tanker None Identified flag; Former Vessel Flag Malta; Vessel Registration Identification IMO 9212888; MMSI 256869000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).”

————————————————————–

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

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Fed Works With Prosecutors On Iran, Other Sanction Issues

August 7, 2012

Bloomberg on August 7, 2012 released the following:

“By Craig Torres

Federal Reserve Board spokeswoman Barbara Hagenbaugh said the central bank is working with prosecutors and the U.S. Treasury’s Office of Foreign Assets Control “on matters involving Iran and other sanctioned entities.”

“We cannot comment on ongoing investigations,” Hagenbaugh said by telephone. Hagenbaugh was responding to a query about accusations that Standard Chartered Plc violated U.S. money- laundering laws over its dealings with Iranian banks.”

————————————————————–

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: