Treasury Designates Alleged Members And Supporters of Transnational Criminal Organizations

July 24, 2013

The U.S. Department of the Treasury on July 24, 2013 released the following:

“New Sanctions Announced Against the Camorra and the Brothers’ Circle

WASHINGTON – The U.S. Department of the Treasury today designated five members of the Italian Camorra, including the mob boss Marco Di Lauro and the fugitive Mario Riccio, as well as two businesses linked to individuals acting on behalf of a key member of the Brothers’ Circle, a large multi-ethnic Eurasian criminal network. These Transnational Criminal Organizations (TCOs) continue to use various methods to conceal the proceeds earned from their illicit activities and maintain access to the international financial system. Today’s actions are the latest in the Treasury Department’s use of executive authorities to expose, undermine, and disrupt these criminal activities which include: money laundering, extortion, drug trafficking, kidnapping and counterfeiting.

“Today’s action against key members of criminal organizations that engage in serious crimes around the world is a continuation of our systematic effort to expose and disrupt these dangerous groups and protect the U.S. financial system from their illicit activity,” said Under Secretary for Terrorism and Financial Intelligence David S. Cohen.

President Obama identified the Camorra, and the Brothers’ Circle, along with the Yakuza and the Zetas, as significant TCOs in the Annex to Executive Order (E.O.) 13581 (Blocking Property of Transnational Criminal Organizations) in July 2011, and he charged the Treasury Department with pursuing additional sanctions against their members and supporters to undermine and interdict their global criminal operations.

Today’s action freezes any assets these individuals and businesses may have within the jurisdiction of the United States and generally prohibits any transactions with them by U.S. persons. To date, the Treasury Department has designated 34 individuals and entities related to TCOs and has exposed their activity ranging from Europe to Asia to the Middle East. Treasury will continue to target additional members and supporters of these groups, as well as identify other significant TCOs, such as MS-13 which was named in October 2012, in order to expose and disrupt their criminal operations and protect the U.S. financial system from abuse.

The Camorra

The Camorra operates internationally and is involved in serious criminal activity, such as money laundering, extortion, alien smuggling, robbery, blackmail, kidnapping, political corruption, and counterfeiting. Italian law enforcement has conducted multiple operations this year to seize Camorra assets, including a single-day seizure of 450 million euros from the Casalesi clan in June. To date, Treasury has designated nine individuals affiliated with the Camorra under E.O. 13581.

The Camorra members designated today have all played a role in the recent inter-clan violence that has wreaked havoc on northern Naples. In October 2012, all five were identified by Italian authorities as involved in the murder of a bystander to the feud. Marco Di Lauro has been on Italy’s Most Wanted List since 2004 for mafia-related activities. Mario Riccio is involved in a drug trafficking business that nets tens of millions of euros every year. Until his capture in January, Antonio Mennetta was in charge of a group responsible for assassinating enemies of a young splinter clan supported by Di Lauro, the “Vanella Grassi” or “Girati”. Mariano Abete, also currently in jail, was arrested for mafia associated activity and conspiracy to deal drugs. Rosario Guarino, implicated in a dozen murders, was arrested in November 2012 for mafia associated activities and drug trafficking. Each of these five individuals were designated for acting for or on behalf of, or providing material support to, the Camorra.

The Brothers’ Circle

The Brothers’ Circle is a multi-ethnic criminal group composed of leaders and senior members of several Eurasian criminal groups largely based in countries of the former Soviet Union but extending to Europe, the Middle East, Africa, and Latin America. To date, Treasury has designated 16 individuals connected with the Brothers’ Circle, including both Brothers’ Circle members and their subordinates, under E.O. 13581. These designated individuals include key member Vladislav Leontyev, as well as two individuals acting for or on his behalf, Aleksandr Manuylov and Lazar Shaybazian. Leontyev, Manuylov, and Shaybazian were designated by Treasury in February 2012. Today, Treasury is taking action against the companies Avuar OOO and Guga Arm SRO because they are owned or controlled by Aleksandr Manuylov and Lazar Shaybazian, respectively. Aleksandr Manuylov is the sole director of Avuar OOO while Lazar Shaybazian is the director, sole board member, and 100 percent owner of Guga Arm SRO.

Identifying Information:

Name: Di Lauro, Marco
DOB: 16 June 1980
POB: Naples, Italy

Name: Riccio, Mario
AKA: Riccio, Mariano
DOB: 28 June 1991
POB: Mugnano di Napoli, Italy

Name: Mennetta, Antonio
DOB: 3 January 1985
POB: Naples, Italy

Name: Abete, Mariano
DOB: 3 April 1991
POB: Naples, Italy

Name: Guarino, Rosario
DOB: 26 June 1983
POB: Naples, Italy

Name: Avuar OOO
AKA: Avuar LLC
Address: 12/120, Komn 51, Ulitsa Demokraticheskaya, Samara 443031, Russia
National ID No.: 1036300456213 (Russia)
alt. National ID No.: 14565711 (Russia)
alt. National ID No.: 6315565439 (Russia)

Name: Guga Arm SRO
AKA: Guga Arm LTD
Address: Dr. Davida Bechera 907/27, Karlovy Vary 36001, Czech Republic
National ID No.: 27994783 (Czech Republic)”

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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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Treasury Sanctions Financial Operatives Allegedly Linked to Los Zetas

July 23, 2013

The U.S. Department of the Treasury on July 23, 2013 released the following:

“Action Targets Individuals Laundering Money for Trevino Morales

WASHINGTON – The U.S. Department of the Treasury today designated two Mexican nationals, Jose Odilon Ramirez Perales and Ismael Lopez Guerrero, pursuant to the Foreign Narcotics Kingpin Designation Act (Kingpin Act) for their ties to Mexico’s violent Los Zetas drug trafficking organization. Ramirez Perales is a powerful financial operative responsible for controlling and laundering tens of millions of dollars in funds smuggled from the U.S. to Mexico for Los Zetas leaders Miguel Trevino Morales and Omar Trevino Morales. Lopez Guerrero collects illicit monies from Los Zetas operations in Nuevo Laredo, and he sends large quantities of smuggled cash to Ramirez Perales for safeguarding and processing in Coahuila, Mexico.

“The momentous arrest of Miguel Trevino Morales, who was captured last week, took place in the early morning hours with two of his closest advisors by his side, including a key accountant. This is another clear example of the central importance of financial operatives within the operational structure of drug cartels,” said Treasury’s Director of the Office of Foreign Assets Control (OFAC) Adam J. Szubin. “Treasury’s action today targets the activities of two other significant financial operatives for Los Zetas. We will continue to support our Mexican partners to target those laundering Los Zetas’ ill-gotten gains.”

Ramirez Perales is wanted in the Southern District of Texas for money laundering relating to drug trafficking. Ramirez Perales and his other co-defendants are subject to the forfeiture of approximately $20 million in the Southern District of Texas. In October 2012, Mexican authorities captured Ramirez Perales, and they arrested Lopez Guerrero after a July 2012 gun battle. Lopez Guerrero, who uses the alias Gilberto Godina Guerrero, was alleged to possess ammunition, drugs, and currency at the time of his arrest. The arrests of these individuals and other high level Los Zetas members such as Miguel Trevino Morales, along with the death of former Zeta leader Heriberto Lazcano-Lazcano, has played a vital role in weakening of the organization.

Today’s action generally prohibits U.S. persons from engaging in any transactions with these individuals and freezes any assets they may have under U.S. jurisdiction.

The President identified Los Zetas as a significant foreign narcotics trafficker pursuant to the Kingpin Act in April 2009. On July 24, 2011, the President named Los Zetas as a significant Transnational Criminal Organization in the Annex to Executive Order 13581 (Blocking Property of Transnational Criminal Organizations). Additionally, OFAC designated Los Zetas leaders Miguel and Omar Trevino Morales on July 20, 2009 and March 24, 2010, respectively. Since 2009, OFAC has designated several dozen key plaza bosses, drug traffickers, and money launderers operating on behalf of Los Zetas using Kingpin Act authorities.

Internationally, OFAC has designated more than 1,200 individuals and entities linked to 103 drug kingpins since June 2000. OFAC designations are part of an ongoing effort to apply financial measures against significant foreign narcotics traffickers and their organizations worldwide. Penalties for violations of the Kingpin Act range from civil penalties of up to $1.075 million per violation to more severe criminal penalties. Criminal penalties for corporate officers may include up to 30 years in prison and fines up to $5 million. Criminal fines for corporations may reach $10 million. Other individuals face up to 10 years in prison and fines pursuant to Title 18 of the United States Code for criminal violations of the Kingpin Act.

For a chart relating to today’s actions click here.”

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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
OFAC SDN Removal Videos:

OFAC Litigation – SDN List Removal

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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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U.S. Seizes $150 Million in Alleged Hezbollah-Linked Cash

August 21, 2012

The Wall Street Journal on August 20, 2012 released the following:

“By Samuel Rubenfeld

U.S. officials said Monday they seized $150 million connected to a scheme in which entities linked to Hezbollah allegedly used the U.S. financial system to launder money through West Africa and back to the group’s base of Lebanon.

The seizure stems from a civil lawsuit filed last year by federal prosecutors in Manhattan against defunct Lebanese Canadian Bank, or LCB, and two Lebanese exchange houses seeking more than $480 million in funds allegedly derived from drug trafficking and other criminal activity passing through the U.S. financial system.

The seizure was reported by The Wall Street Journal, and there’s more here.

Hezbollah is a U.S.-designated foreign terrorist organization. The group’s leadership has denied engaging in money laundering to finance its activity.

Prosecutors said Monday they seized $150 million from a New York correspondent account of Lebanon’s Banque Libano Francaise SAL, or BLF. Société Générale de Banque au Liban, which bought LCB in September 2011 for $580 million, paid for part of the transaction through BLF. The seized funds are substitutes for the money in the LCB account in escrow at BLF, prosecutors said.

The warrants to seize the funds were issued August 15, but made public Monday. Neither BLF nor Société Générale de Banque au Liban were accused of wrongdoing, prosecutors said.

“Money is the lifeblood of terrorist and narcotics organizations, and while banks which launder money for terrorists and narco-traffickers may be located abroad, today’s announcement demonstrates that those banks and their assets are not beyond our reach,” said Manhattan U.S. Attorney Preet Bharara in a statement.

A lawyer for LCB declined to comment to the Journal.

The U.S. Treasury Department designated LCB as a “primary money-laundering concern” under the Patriot Act in February 2011, accusing it at the time of facilitating money laundering by a network of drug traffickers spanning South America, Europe, the Middle East and West Africa.

Société Générale de Banque au Liban acquired LCB’s assets and liabilities following the Treasury’s finding.

According to the civil complaint filed last year, the alleged scheme involved cash sent from Lebanon to the U.S. between January 2007 and early 2011 to buy used cars that were later sold in West Africa for cash.

The money from from the car sales was then allegedly transferred back to Lebanon with proceeds from narcotics trafficking and other crimes, prosecutors said in the complaint.

Correction: The seized funds came from the New York correspondent account of Lebanon’s Banque Libano Francaise SAL, not from a U.S. account at Société Générale de Banque au Liban.”

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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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Specially Designated Narcotics Trafficking Kingpin [SDNTK] Entries Added to OFAC’s SDN List on August 15, 2012

August 15, 2012

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

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

ALMACEN PICIS, 3 Avenida 19-59, Local 14, Zona 1, Guatemala City, Guatemala; Registration ID 80617 (Guatemala) [SDNTK].

ALQUILERES ROSSELL, Km 12.5 Carrertera Al Salvador, Santa Rosalia, Condominio La Laguna, Casa 1, Guatemala, Guatemala; Registration ID 388175 (Guatemala) [SDNTK].

AUTO HOTEL PUNTO CERO, Kilometro 49.5 Carretera A El Salvador, Aldea El Cerinal, Barberena, Santa Rosa, Guatemala; Registration ID 404256 (Guatemala) [SDNTK].

BODEGAS BANYOLAS, 14 Avenida 7-12 Zona 14, Centro Empresarial La Villa Bodega 23, Guatemala City, Guatemala; Registration ID 71152 (Guatemala) [SDNTK].

BOUTIQUE MARLLORY, KM 54.5 Carretera Al Salvador, Santa Rosa, Barberena, Guatemala; Registration ID 159497A (Guatemala) [SDNTK].

BRODWAY COMMERCE INC., 17 Calle A 7-21, Zona 10, Guatemala City, Guatemala; Registration ID 60832 (Guatemala) [SDNTK].

CABOMARZO, 3A Calle 3-46, Zona 2, Residenciales Valles De Maria, Villa Nueva, Guatemala; Registration ID 89276 (Guatemala) [SDNTK].

CASA VOGUE, Km 14.1 Carretera El Salvador, Centro Comercial Paseo San Sebastian Local 92, Guatemala City, Guatemala [SDNTK].

CASTELLANOS CHACON, Christina Stetanel (a.k.a. “CHRISTA CASTELLANOS”); DOB 17 Jun 1991; nationality Guatemala; Passport 133374328 (Guatemala) (individual) [SDNTK].

CORPORACION DAIMEX S.A., 14 Avenida 7-12, Zona 14, Bodega No. 22, Empresarial La Villa, Guatemala City, Guatemala; Registration ID 36397 (Guatemala) [SDNTK].

DE DEL PINAL, Maria Corina (a.k.a. SAENZ LEHNHOFF, Maria Corina; a.k.a. SAENZ LEHNHOFF, Maria Gabriela; a.k.a. SAENZ PINAL, Maria Corina); DOB 19 May 1965; POB Guatemala; nationality Guatemala; Passport 31486K (Guatemala) (individual) [SDNTK] Linked To: INMOBILIARIA DATEUS; Linked To: WALNUTHILL; Linked To: CABOMARZO; Linked To: GRUPO MPV; Linked To: DELPSA; Linked To: BRODWAY COMMERCE INC.; Linked To: CASA VOGUE.

DELPSA, 2 Calle 25-80, Zona 15, Vista Hermosa II, Apt. 800, Guatemala City, Guatemala; Registration ID 200766 (Guatemala) [SDNTK].

DIGITAL SYS ADVISORS, 14 Avenida 7-12 Zona 14, Bodega 22, Empresarial La Villa, Guatemala City, Guatemala; Registration ID 68326 (Guatemala) [SDNTK].

DISTRIBUIDORA ROSSELL, Calzada Roosevelt KM, 13 40-31, Zona 11, Guatemala City, Guatemala; Registration ID 388221 (Guatemala) [SDNTK].

ESTRUCTURAS METALICAS, CIRCULARES Y ORTOGONALES (a.k.a. “EMCO”), Aldea El Durazno Lote 12 Kilometro 8.5, Antigua Ruta A San Pedro Ayampuc, Chinautla, Guatemala; Registration ID 45703 (Guatemala) [SDNTK].

FARFAR, 14 Avenida 7-12 Zona 14, Bodega 22, Empresarial La Villa, Guatemala City, Guatemala; Registration ID 75563 (Guatemala) [SDNTK].

FERNAPLAST, Km 12-5 Ruta Al Atlantico, Apto. A, Zona 18, Guatemala City, Guatemala; Registration ID 188919A (Guatemala) [SDNTK].

GRUPO MPV, Km 14.1 Carretera El Salvador, Centro Comercial Paseo San Sebastian Local 92, Guatemala City, Guatemala; Registration ID 55544 (Guatemala) [SDNTK].

HACIENDA SANTA INES, 3 Avenida 13-46 Zona 1, Guatemala City, Guatemala; Registration ID 319945 (Guatemala) [SDNTK].

HUERTAS Y HORTALIZAS, Lote 10 Aldea Las Vacas, Zona 16, Guatemala City, Guatemala; Registration ID 49720 (Guatemala) [SDNTK].

IMPORTADORA BORRAYO LASMIBAT, 13 Av 26-49, San Jose Las Rosas Zona 8, Guatemala City, Guatemala; Registration ID 135027 [SDNTK].

INMOBILIARIA DATEUS, 1era Avenida 7-60, Zona 14, Apartamento 1602 Del Edificio Tadeus, Guatemala City, Guatemala; Registration ID 84101 (Guatemala) [SDNTK].

INVERSIONES A&E, 8 Avenida 16-49 Zona 10, Edificio San Ignacio Apto. 2-A, Guatemala City, Guatemala; Registration ID 43339 (Guatemala) [SDNTK].

OPERADORA CORPORATIVA DE NEGOCIOS (a.k.a. “OCN”), Diagnol 6 No. 16-01, Zona 10, Guatemala City, Guatemala [SDNTK].

SAENZ LEHNHOFF, Maria Corina (a.k.a. DE DEL PINAL, Maria Corina; a.k.a. SAENZ LEHNHOFF, Maria Gabriela; a.k.a. SAENZ PINAL, Maria Corina); DOB 19 May 1965; POB Guatemala; nationality Guatemala; Passport 31486K (Guatemala) (individual) [SDNTK] Linked To: INMOBILIARIA DATEUS; Linked To: WALNUTHILL; Linked To: CABOMARZO; Linked To: GRUPO MPV; Linked To: DELPSA; Linked To: BRODWAY COMMERCE INC.; Linked To: CASA VOGUE.

SAENZ LEHNHOFF, Maria Gabriela (a.k.a. DE DEL PINAL, Maria Corina; a.k.a. SAENZ LEHNHOFF, Maria Corina; a.k.a. SAENZ PINAL, Maria Corina); DOB 19 May 1965; POB Guatemala; nationality Guatemala; Passport 31486K (Guatemala) (individual) [SDNTK] Linked To: INMOBILIARIA DATEUS; Linked To: WALNUTHILL; Linked To: CABOMARZO; Linked To: GRUPO MPV; Linked To: DELPSA; Linked To: BRODWAY COMMERCE INC.; Linked To: CASA VOGUE.

SAENZ PINAL, Maria Corina (a.k.a. DE DEL PINAL, Maria Corina; a.k.a. SAENZ LEHNHOFF, Maria Corina; a.k.a. SAENZ LEHNHOFF, Maria Gabriela); DOB 19 May 1965; POB Guatemala; nationality Guatemala; Passport 31486K (Guatemala) (individual) [SDNTK] Linked To: INMOBILIARIA DATEUS; Linked To: WALNUTHILL; Linked To: CABOMARZO; Linked To: GRUPO MPV; Linked To: DELPSA; Linked To: BRODWAY COMMERCE INC.; Linked To: CASA VOGUE.

SISTEMAS CONSTRUCTORES (a.k.a. “SICONSA”), Lote 10, Aldea Las Vacas, Zona 16, Guatemala City, Guatemala; Registration ID 34279 (Guatemala) [SDNTK].

WALNUTHILL, Diagnol 6 10-01, Zona 10, Centro Gerencial Las Margaritas, Torre II, Of. 301-B, Guatemala City, Guatemala; Registration ID 80886 (Guatemala) [SDNTK].

“CHRISTA CASTELLANOS” (a.k.a. CASTELLANOS CHACON, Christina Stetanel); DOB 17 Jun 1991; nationality Guatemala; Passport 133374328 (Guatemala) (individual) [SDNTK].

“EMCO” (a.k.a. ESTRUCTURAS METALICAS, CIRCULARES Y ORTOGONALES), Aldea El Durazno Lote 12 Kilometro 8.5, Antigua Ruta A San Pedro Ayampuc, Chinautla, Guatemala; Registration ID 45703 (Guatemala) [SDNTK].

“OCN” (a.k.a. OPERADORA CORPORATIVA DE NEGOCIOS), Diagnol 6 No. 16-01, Zona 10, Guatemala City, Guatemala [SDNTK].

“SICONSA” (a.k.a. SISTEMAS CONSTRUCTORES), Lote 10, Aldea Las Vacas, Zona 16, Guatemala City, Guatemala; Registration ID 34279 (Guatemala) [SDNTK].

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Treasury Applies Additional Sanctions to Guatemalan Drug Trafficking Operation

8/15/2012

WASHINGTON – The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced the designation of two individuals and 24 entities with ties to previously-designated Guatemalan trafficker Marllory Dadiana Chacon Rossell or other designated individuals as Specially Designated Narcotics Traffickers (SDNTs). Today’s action, taken pursuant to the Foreign Narcotics Kingpin Designation Act (Kingpin Act), prohibits U.S. persons from conducting financial or commercial transactions with these entities and individuals and any assets the designees may have under U.S. jurisdiction are frozen.

The two individuals designated today are Guatemalan nationals Christina Stetanel Castellanos Chacon (a.k.a. Cristha Castellanos), who is Chacon Rossell’s daughter, and Maria Corina Saenz Lehnhoff (a.k.a. Maria Corina de Del Pinal). Both are responsible for laundering narcotics proceeds on behalf of Marllory Chacon Rossell. Among the 24 entities designated today are Auto Hotel Punto Cero, a hotel in Barberena, Guatemala; Sistemas Constructores, a construction company; Importadora Borrayo Lasmibat, an import-export company; Boutique Marllory, a clothing store and; Casa Vogue, a household items store.

“Targeting the corporate and financial network of Marllory Chacon and her associates is at the core of our efforts to degrade these dangerous drug trafficking organizations,” said OFAC Director Adam J. Szubin. “By designating additional elements of the Chacon Rossell network, OFAC continues to undermine the organization’s ability to launder narcotics proceeds.”

Marllory Dadiana Chacon Rossell leads a drug trafficking and money laundering organization based out of Guatemala with operations in Honduras and Panama that supplies Mexican drug cartels, including Los Zetas. OFAC designated Chacon Rossell as an SDNT in January 2012, along with three of her top associates, Jorge Andres Fernandez Carbajal, Hayron Eduardo Borrayo Lasmibat, and Mirza Silvana Hernandez De Borrayo, and four entities located in Guatemala and Panama. Chacon Rossell is responsible for transshipping thousands of kilograms of cocaine per month and is believed to launder tens of millions of U.S. dollars in narcotics proceeds each month.

OFAC coordinated with the Drug Enforcement Administration on this investigation. Today’s action is part of ongoing efforts pursuant to the Kingpin Act to apply financial measures against significant foreign narcotics traffickers and their organizations worldwide. The Treasury Department has designated more than 1,100 individuals and entities pursuant to the Kingpin Act since June 2000.

“DEA and the Treasury Department are attacking drug trafficking organizations at every level, using the law enforcement tools necessary to dismantle the financial networks of these dangerous criminal groups,” said DEA Chief of Financial Operations John Arvanitis. “This organization’s ability to launder drug trafficking proceeds will be severely hindered as a result of this designation.”

Penalties for violations of the Kingpin Act range from civil penalties of up to $1.075 million per violation to more severe criminal penalties. Criminal penalties for corporate officers may include up to 30 years in prison and fines up to $5 million. Criminal fines for corporations may reach $10 million. Other individuals face up to 10 years in prison and fines pursuant to Title 18 of the United States Code for criminal violations of the Kingpin Act.

To view a chart of the Chacon Rossell affiliates, click here.”

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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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In Laundering Case, a Lax Banking Law Obscured Money Flow

August 9, 2012

The New York Times on August 8, 2012 released the following:

“By JESSICA SILVER-GREENBERG and EDWARD WYATT

The list of global banks that have been accused in recent years of laundering foreign transactions totaling billions of dollars has been growing — Credit Suisse, Lloyds, Barclays, ING, HSBC — and now Standard Chartered.

The details in each case are different, with the international banks suspected of using their American subsidiaries to process tainted money for clients that included Iran, Cuba, North Korea, sponsors of terrorist groups and drug cartels.

What the cases have in common is that the accused banks took advantage of a law that was not changed until 2008 and that allowed banks to disguise client identities and move their money offshore. The cases, including one filed this week by New York’s banking regulator against Standard Chartered, also cast a harsh light on just how much activity with Iran was permitted in the years leading up to 2008 and whether the practices had violated the spirit, if not the letter, of the law.

Foreign banks until 2008 were allowed to transfer money for Iranian clients through their American subsidiaries to a separate offshore institution. In the so-called U-turn transactions, the banks had to provide scant information about the client to their American units as long as they had thoroughly vetted the transactions for suspicious activity. Suspecting that Iranian banks were financing nuclear weapons and missile programs, the loophole was finally closed in 2008.

The new money-laundering claims made by the New York Department of Financial Services against Standard Chartered are particularly embarrassing for the Treasury Department, because they show how, until 2008, foreign banks could collaborate with their Iranian clients to circumvent United States sanctions, said Jimmy Gurulé, a former Treasury Department official who is a law professor at the University of Notre Dame.

Standard Chartered, as part of a strategy to ignore regulations imposed by a division of the Treasury Department, schemed with its Iranian clients to omit crucial details from money-transfer paperwork, according to a regulatory order filed Monday. An e-mail from a lawyer to bank executives in 2001 said that payment instructions for Iranian clients “should not identify the client or the purpose of the payment,” according to the order.

The strategy of masking client details was driven, in part, by a desire for speed, according to law enforcement officials involved in the money-laundering cases. Transactions with certain risky clients, like the Iranians, were subject to much more rigorous vetting. To avoid the holdup, the officials said, some foreign banks willfully removed the names.

Since January 2009, the Justice Department, Treasury and other government entities have brought charges against five foreign banks — the British banks Lloyds and Barclays; the Dutch banks Credit Suisse and ABN Amro, now the Royal Bank of Scotland; and ING Bank of Amsterdam. The British bank HSBC is also under investigation by United States authorities for suspected money-laundering violations connected to Iran, Mexico, Saudi Arabia, Cuba and North Korea, and the bank has set aside $700 million to cover potential fines.

The settlements with the five banks generally included deferred prosecution agreements along with a substantial forfeiture of assets comparable in size to the basket of illegal transactions the banks engaged in. The five cases, which resulted from bank actions from 1995 through 2007, produced forfeitures of $2.3 billion over the last three and a half years. About half of that money went to Treasury and half to other entities, including the Manhattan district attorney’s office, which joined the Justice Department in most of the settlements.

So far, the Standard Chartered case is playing out entirely differently. To start with, action against the bank on Monday was brought by a single regulator, Benjamin M. Lawsky, a former prosecutor who now leads the New York Department of Financial Services. That is virtually unprecedented, since the vast majority of money-laundering charges come from regulators acting in concert.

The federal agencies are still investigating Standard Chartered and are debating just how expansive the suspected wrongdoing was. Mr. Lawsky claims the bank processed $250 billion in tainted money while cloaking the identities of its Iranian clients by stripping their names from paperwork. Some federal authorities, though, believe that the amount is closer to the $14 million that Standard Chartered acknowledges did not comply with regulations.

It is unclear whether the bank will settle with regulators or continue to fight. Standard Chartered must appear next week before Mr. Lawsky to explain the apparent violations and why it should not have its New York license revoked.

The divergent views on the bank’s culpability stem, in part, from the murkiness of the law governing how foreign institutions processed transactions with Iran.

Until 2008, American economic sanctions had a large exception for Iran because the Middle Eastern nation had such a vast oil business with the United States. The loophole permitted the U-turn transactions, allowing foreign institutions to route money to a bank in the United States, which would then transfer the money immediately to a different foreign institution.

Since Monday, Standard Chartered has fiercely argued that its transactions on behalf of Iranian banks and corporations fell squarely within that loophole. But Mr. Lawsky is largely basing his case on claims that the bank violated the law by covering up the identity of its Iranian clients and thwarting American efforts to detect money laundering.

In the settlements with the five banks since 2009, federal authorities and the Manhattan prosecutor accused the banks of “stripping” identifying information from some of the transactions that would have shown they were subject to sanctions and should not be allowed.

For example, in Lloyds’s $217 million settlement in 2009, senior bank managers warned colleagues in 2002 against “stripping” information from transactions referencing Iran, according to court records. In response, the records say, Lloyds simply began to “instruct Iranian banks on how to ‘clean’ payment instructions in which they were the originating bank to avoid detection” by Treasury Department filters.

The stripping constituted criminal conduct, the Justice Department said, when the transfers from sanctioned countries terminated in the United States — rather than taking a U-turn and heading back offshore. By ending in America, the transactions were subjected to stricter security standards, law enforcement officials said. In a letter sent Wednesday from Adam J. Szubin, director of Treasury’s Office of Foreign Assets Control, to Britain’s Treasury office, the department explained its enforcement efforts both before and after the 2008 changes. Now, all cross-border transfers require “the inclusion of complete originator and beneficiary information,” according to the letter, which was obtained by The New York Times.

United States banks were involved in the pre-2008 transactions only as an intermediary, and American banks have generally not been charged with violations similar to those brought against the five foreign banks. Because American banks were prohibited from being the beginning or ending party in transactions involving Iran and other sanctioned countries, they would not have been involved in the conduct that got the foreign banks into trouble.

Since the tighter sanctions went into effect, there have been no charges brought on post-2008 conduct, although Treasury’s letter says that investigations are ongoing.

Gina Talamona, a Justice Department spokeswoman, said that the lack of recent illegal conduct is because the settlements with foreign banks “required the banks to implement rigorous compliance programs and other safeguards” against further violations of sanctions. She said that the department’s enforcement program “has had a significant impact on banking industry practices involving sanctions.””

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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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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.”

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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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Regulator Says British Bank Helped Iran Hide Deals

August 7, 2012

The New York Times on August 6, 2012 released the following:

“By JESSICA SILVER-GREENBERG

Using its New York-based operations, a major British bank schemed with the Iranian government for nearly a decade to launder $250 billion, leaving the United States financial system vulnerable to terrorists and corrupt regimes, New York’s top banking regulator charged on Monday.

The New York State Department of Financial Services accused Standard Chartered, which the agency called a “rogue institution,” of masking more than 60,000 transactions for Iranian banks and corporations, motivated by the millions of dollars it reaped in fees.

Senior management at the 150-year-old bank used the New York branch “as a front for prohibited dealings with Iran — dealings that indisputably helped sustain a global threat to peace and stability,” according to a regulatory order sent to the bank. The order requires the bank to explain the apparent violations of law in a hearing later this month and justify why its license to operate in New York shouldn’t be revoked.

The bank said Monday night that it “strongly rejects the position and portrayal of facts” by the agency.

The Federal Bureau of Investigation said that it had an open investigation into money laundering at Standard Chartered. In the order, regulators paint a vivid picture of a cover-up that included the code name “Project Gazelle,” money flowing to Iran’s central bank, United States executives warning of “criminal liability,” and a manual that taught employees how to automate the masking of a rising number of illegal transactions.

The accusations against Standard Chartered come as United States officials work to crack down on the flow of money to foreign countries, companies and individuals connected to terrorism, weapons of mass destruction and drug trafficking.

Beyond the dealings with Iran, the banking regulator said it had discovered evidence that Standard Chartered operated “similar schemes” to do business with other countries under United States sanctions, including Myanmar (formerly Burma), Libya and Sudan.

Earlier Monday, a spokesman for Standard Chartered said the bank was reviewing its “historical U.S. sanctions compliance and is discussing that review with U.S. enforcement agencies and regulators.”

But the order accuses senior executives at the bank of suppressing complaints. For example, in 2006, according to the order, the bank’s chief executive for the Americas wrote his bosses in London that the transactions had “the potential to cause very serious or even catastrophic reputational damage to the group.”

According to the order, the response was hostile, denigrated Americans and asked: “Who are you to tell us, the rest of the world, that we’re not going to deal with Iranians.” The department of financial services, led by superintendent Benjamin M. Lawsky, said it was “impossible to know” how much of the money might have been used by Iran to finance its nuclear program or to support terrorist organizations.

Mr. Lawsky said that the department, which examined more than 30,000 internal memos, e-mails and other documents in its nine-month investigation, will hold hearings to determine any financial penalty.

Standard Chartered is the latest in a series of global banks to be accused of facilitating illegal flows of money from outside the United States. In July, a Senate panel issued a report that accused HSBC of being used by Mexican drug cartels to funnel cash back into the United States, by Saudi Arabian banks with terrorist ties that needed access to dollars and by Iranians who wanted to circumvent United States sanctions.

In June, the Justice Department and the New York County district attorney’s office reached a $619 million settlement with ING Bank over accusations that it had illegally moved billions of dollars into the United States for sanctioned Cuban and Iranian entities.

The “apparent fraudulent and deceptive conduct” by Standard Chartered occurred from 2001 to 2010, the order said, and was particularly “egregious,” because some of the transactions were being processed even as the bank was under formal oversight by New York banking regulators from 2004 to 2007.

Standard Chartered, which is based in London, relies for most of its profit on business in Africa, Asia and the Middle East.

Before 2008, the federal government permitted money to be transferred through the United States from one non-American based entity to another, but only after being thoroughly vetted to detect suspicious activity. In so-called U-turn transactions, a foreign institution routes money to a bank in the United States, which transfers the money immediately to a separate foreign institution.

Suspecting that Iran was using its banks — including the Central Bank of Iran/Markazi, Bank Saderat and Bank Melli — to finance nuclear weapons and missile programs, the policy toward Iran changed and the transactions were banned entirely in 2008.

The order on Monday cited those Iranian state-owned banks as clients of Standard Chartered.

Standard Chartered disputed the accusations and said that “well over 99.9 percent of the transactions relating to Iran complied with the U-turn regulations.” Those that did not comply amounted to less than $14 million, the bank said.

The bank said in its statement late Monday that it had kept federal and state authorities apprised of the review it initiated in 2010. It said that it “did not identify a single payment” connected to a terrorist entity or organization and that it had “ceased all new business with Iranian customers” five years ago.

The apparent illegal activity stretched back to 1995 after President Bill Clinton levied sanctions against Iran. At the time, the general counsel of Standard Chartered e-mailed the bank’s chief compliance officer a plan to ignore regulations imposed by a division of the Treasury Department, according to the order.

In the e-mails included in the order, the executives said a memo containing the plan “MUST NOT be sent to the U.S.,” to prevent prosecution.

That strategy of flouting the United States law was commonplace by 2001, Mr. Lawsky said. An e-mail from a lawyer to bank executives in 2001 said that payment instructions for Iranian clients “should not identify the client or the purpose of the payment.”

One Iranian client, for example, was told to use “NO NAME GIVEN” in paperwork to transfer money, the order said. That way, the money transfer could escape scrutiny and “not appear to N.Y. to have come from an Iranian bank,” a 2003 e-mail from a Standard Chartered official said.

In a strategy called Project Gazelle, the bank devised to forge “new relationships with Iranian companies” and intermediaries “in oil- and gas- related businesses,” a memo from 2005 included in the order said.

The bank’s management created a formal operating manual called “Quality Operating Procedure Iranian Bank Processing,” that showed staff members how to strip off information that might tie them to the sanctioned Iranian institutions.

The bank came under scrutiny from the Federal Reserve Bank of New York in 2003 after regulators discovered deficiencies in monitoring its transactions.

As a result, the bank entered a formal agreement with regulators that it strengthen its oversight and bring in an independent consultant to inspect transactions from July 2002 to October 2004.

Even the independent monitoring, by Deloitte & Touche, was perverted, according to Mr. Lawsky. In 2005, at the behest of the bank, Deloitte agreed to omit critical transactions from its report to regulators. “This is too much and too politically sensitive for both SCB and Deloitte. That is why I drafted the watered-down version,” a Deloitte executive said in a 2005 e-mail in the order.

Deloitte denies it aided the bank. The consultant “performed its role as independent consultant properly and had no knowledge of any alleged misconduct by bank employees,” Jonathan Gandal, a Deloitte spokesman said in a statement. “Allegations otherwise are unsupported by the facts.” In its last examination of the bank, in 2011, the state’s Department of Financial Services said it had found “continuing and significant” failures in complying with bank secrecy and money laundering laws.”

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

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————————————————————–

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition Defense, OFAC SDN Sanctions Removal, International Criminal Court Defense, and US Seizure of Non-Resident, Foreign-Owned Assets. Because we have experience dealing with INTERPOL, our firm understands the inter-relationship that INTERPOL’s “Red Notice” brings to this equation.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.

————————————————————–

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Viktor Bout associates exploited flaws in international law, UN study finds

July 18, 2012

The Guardian on July 17, 2012 released the following:

“Two of the convicted arms dealer’s lieutenants nearly set up fresh gunrunning ring despite being under government watch

[By] Karen McVeigh in New York

Former associates of convicted international arms dealer Viktor Bout exploited loopholes to set up a global trafficking ring with their sights set on selling weapons to war-torn countries like Sudan, Somalia, Iran and possibly Syria, an investigation has revealed.

The report, by Kathi Lynn Austin, a former UN arms investigator and executive director of Conflict Awareness Project (Cap) shows how close two of Bout’s lieutenants came to establishing a fresh gunrunning network in the wake of his conviction last year, despite being under US government watch or subject to US sanctions.

At a press conference on Tuesday at the UN in New York, where representatives from 190 countries are midway through negotiations over the first Arms Trade Treaty, Austin said: “These brokers go to extreme lengths to reap profits form conflict, atrocity and UN sanctions-busting. As we speak, gunrunners are out there exploiting every loophole in a global arms trade that is out of control.”

The six-week investigation describes how “classic techniques” of illicit arms brokers were used including flags of convenience, money laundering and establishing multiple layers of “shell companies” to evade detection and accountability.

The investigation also uncovered new techniques, including a switch away from a previous reliance on aging Russian aircraft to predominately western passenger planes.

The men at the heart of the investigation are two Russians, Sergei Denisenko and Andrei Kosolapov, former associates of Bout, whose gunrunning networks enabled the flow of arms into African conflict including the Democratic Republic of Congo, Angola, and Sudan.

It shows how, even with Bout in prison and US sanctions against them, they were able to circumvent laws and set up US business partners. Denisenko is on the US Special Designated Nationals (SDN) List enforced by the department of treasury, because of his past trafficking activities in Liberia, according to the report.

His SDN listing prohibits US companied dealing with him. Kosolapov is on the US Visas Viper list, a watch list used internationally by the state department to track known or suspected terrorists, according to the report titled Viktor Bout’s Gunrunning Sucessors: A Lethal Game of Catch Me if you Can.

Their plan was to lease a US-registered plane that could be used for arms transfers while flying under a Mauritian aviation certificate.

The report found that the Denisenko-Kosolapov partnership engaged a number of subcompanies and business partners including US, UK, Finnish and Mauritian companies.

One aircraft was located in Bangor, Maine. Human rights advocacy group Human Rights First said the report demonstrated gaps in implementation and enforcement of US sanction regimes.

Sadia Hameed, of Human Rights First, said: “Countries that may have more robust regulations, like the United States, are still unable to singlehandedly prevent illicit arms trafficking operations.”

She said more could have been done by the US to share information with their embassy in Mauritius about Denisenkio and Kosolapov and that it should do more to ensure SDN guidelines are followed by US companies.

“The fact that through Kathi Lynn Austin’s investigations she was able to uncover that they very nearly aquired a US-registered plane and that that plane was intended to service whatever the forward activities of the network were, points out gaps in due diligence of sanctions.”

A US company illegally provided parts and maintenance for the aircraft leased by the pair, according to the report and US pilots were lined up to fly it, which is also illegal.

In early July, the Mauritius Department of Civil Aviation denied the Denisenko-Kosalopov operations application for an Air Operation Certificate – which any plane needs to be able to fly, effectively stopping the operation.

“The multi-jurisdictional nature of arms trafficking rings is why we need a strong arms control, “said Austin. “The Mauritian government said, ‘How were we to know that this US individual was on a designated list?’ A strong arms control treaty would identify who the criminals are and who the traders are.”

In a statement, a spokesman for the US treasury department said: “Sergei (or Serguei) Denissenko was sanctioned by OFAC (Office of Foreign Assets Control) for being involved in two of Bout’s front companies – San Air General Trading FZE (Ajman, UAE; Richardson, Texas) and also with Centrafricain Airlines. US firms are prohibited from doing business with him as with any other sanctioned parties. OFAC does not have an Andrei Kosolapov on its SDN list.”

Campaigners for arms control expressed concern that, after an opening week characterised by delays, international delegates still do not have the basis for negotiations on most of the key elements of the treaty. The optimistic view is that there will be a negotiating text by Wednesday.

The Arms Trade Treaty faces opposition from Egypt, Syria, Algeria, Iran, Cuba and North Korea. However, Russia, China, the UK, France and the US have issued some joint statements in support. The US would like to see ammunition removed from the treaty and wants to water down the rule on human rights.”

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

OFAC Litigation – SDN List Removal

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OFAC SDN Removal Attorneys

————————————————————–

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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Top Sanctions Official Says Pace To Continue

March 19, 2012

The Wall Street Journal on March 19, 2012 released the following:

“By Samuel Rubenfeld

The pace of sanctions announcements will continue, a top Obama administration official said.

Adam Szubin, director of Treasury’s Office of Foreign Assets Control, said Monday at a conference of anti-money laundering industry officials that Iran and Syria will be the focus as the year goes on, with emphasis on the international dimensions on key measures.

He said OFAC is also looking at legislation emerging from Congress on Iran and Syria, and how the office would implement it.

Szubin’s remarks opened the 17th Annual International Anti-Money Laundering Conference in Hollywood, Fla.

He said the practice by financial institutions of “stripping data and routing transactions on behalf of sanctioned parties” has mostly abated, saying that is a result of a slew of enforcement actions and because the industry decided doing it isn’t consistent with best practices.

“This is not to say there won’t be any more cases announced because we take this conduct very seriously and where we have cases we will pursue them, but the issue is mostly closed,” Szubin said.

Reviewing the past 16 months of sanctions, Szubin said a month hasn’t gone by when OFAC hasn’t make a major announcement such as expanding regulations, or implementing and dismantling an entire sanctions program, as the office did on Libya.

He said the Libya program, which found $30 billion in a matter of hours, was among the most gratifying things he’s ever done.”

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

OFAC Litigation – SDN List Removal

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OFAC SDN Removal Attorneys

————————————————————–

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN Sanctions Removal.

The author of this blog is Douglas McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.