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

June 6, 2013

The U.S. Department of the Treasury on June 6, 2013 released the following:

“OFFICE OF FOREIGN ASSETS CONTROL

Specially Designated Nationals List Update:

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

AL-MASLI, ‘Abd-al-Hamid (a.k.a. AL-DARNAVI, Hamza; a.k.a. AL-DARNAWI, Abu-Hamzah; a.k.a. AL-DARNAWI, Hamza; a.k.a. AL-DARNAWI, Hamzah; a.k.a. AL-MASLI, ‘Abd al-Hamid Muhammad ‘Abd al-Hamid; a.k.a. DARNAVI, Hamza; a.k.a. DARNAWI, Abdullah; a.k.a. DARNAWI, Hamza; a.k.a. DARNAWI, Hamzah; a.k.a. DIRNAWI, Hamzah; a.k.a. MASLI, Hamid; a.k.a. MUSALLI, ‘Abd-al-Hamid), Waziristan, Federally Administered Tribal Areas, Pakistan; DOB 1976; POB Darnah, Libya; alt. POB Danar, Libya; nationality Libya (individual) [SDGT].”

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

OFAC Litigation – SDN List Removal

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

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

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

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC): “Government of Iran Listings; Non-proliferation Designations; Iranian Financial Sanctions Regulations Identifications”

May 29, 2013

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

“OFFICE OF FOREIGN ASSETS CONTROL
Specially Designated Nationals Update

For more information on the Seifollah Jashsaz designation please visit this link.

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

BAHADORI, Masoud; nationality Iran; Passport T12828814 (Iran); Managing Director, Petro Suisse Intertrade Company (individual) [IRAN].

BAZARGAN, Farzad; DOB 03 Jun 1956; Passport D14855558 (Iran); alt. Passport Y21130717 (Iran); Managing Director, Hong Kong Intertrade Company (individual) [IRAN].

BUJAR, Farhad (a.k.a. BOUJAR, Farhad); nationality Iran; Passport R10789966; Managing Director, TESA (individual) [NPWMD] [IFSR].

GHALEBANI, Ahmad (a.k.a. GHALEHBANI, Ahmad; a.k.a. QALEHBANI, Ahmad); DOB 01 Jan 1953 to 31 Dec 1954; Passport H20676140 (Iran); Managing Director, National Iranian Oil Company; Director, Hong Kong Intertrade Company; Director, Petro Suisse Intertrade Company (individual) [IRAN].

JASHNSAZ, Seifollah (a.k.a. JASHN SAZ, Seifollah; a.k.a. JASHNSAZ, Seyfollah); DOB 01 Mar 1958 to 31 Mar 1958; nationality Iran; Passport R17589399 (Iran); Chairman & Director, Naftiran Intertade Co. (NICO) Sarl; Chairman & Director, Naft Iran Intertade Company Ltd.; Director, Hong Kong Intertrade Company; Chairman & Director, Petro Suisse Intertrade Compay (individual) [IRAN].

MAHDAVI, Ali; DOB 21 Apr 1967; citizen Iran (individual) [NPWMD] [IFSR].

MOZAFFARINIA, Reza (a.k.a. MOZAFARI-NIYA, Reza; a.k.a. MOZAFARNIA, Reza; a.k.a. MOZAFFARI NIA, Reza; a.k.a. MOZAFFARINIA HOSEIN, Reza; a.k.a. MOZAFFARI-NIA, Reza; a.k.a. MOZAFFARI-NIYA, Reza; a.k.a. MOZZAFARNIA, Dr. Reza); DOB 1959; POB Isfahan, Iran; Deputy Defense Minister and Dean of Malek Ashtar University (individual) [NPWMD] [IFSR].

NIKOUSOKHAN, Mahmoud; DOB 01 Jan 1961 to 31 Dec 1962; nationality Iran; Passport U14624657 (Iran); Finance Director, National Iranian Oil Company; Director, Hong Kong Intertrade Company; Director, Petro Suisse Intertrade Company (individual) [IRAN].

PARVARESH, Farhad Ali; DOB Dec 1957; nationality Iran (individual) [NPWMD] [IFSR].

POURANSARI, Hashem; nationality Iran; Passport B19488852 (Iran); Managing Director, Asia Energy General Trading (individual) [IRAN].

VAZIRI, Hossein Nosratollah (a.k.a. VAZIRI, Ahmad; a.k.a. VAZIRI, Ahmed), 3-C-C Impiana Condo Jalan, Ulu Klang, Kuala Lumpur, Malaysia; DOB 21 Mar 1961; POB Damghan, Iran; nationality Iran; Passport R19246338 (Iran) (individual) [NPWMD] [IFSR].

YAZDI, Bahareh Mirza Hossein (a.k.a. YAZDI, Betty); DOB 26 Jun 1978; citizen United Kingdom (individual) [NPWMD] [IFSR].

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

ABAN AIR (a.k.a. ABAN AIR CO JPS), No.14, Imam Khomeini Airport, Airport Cargo Terminal, Tehran, Iran; No.1267, Vali Asr Avenue, Tehran 1517736511, Iran; Unit 7, Marlin Park, Central Way, Feltham TW14 OXD, United Kingdom; No.53 Molla Sadra St. Vanak Square, Tehran 19916 14661, Iran; No 7 & 8, Main Dnata Building, Dubai Airport Free Zone, Dubai, United Arab Emirates; Website http://www.abanair.com; Email Address info@abanair.com [NPWMD] [IFSR].

ANDISHEH ZOLAL, 42 Niam Street, Shariati Avenue, P.O. Box 15875-4159, Tehran 19481, Iran [NPWMD] [IFSR].

DFS WORLWIDE (a.k.a. DFS WORLDWIDE FZCO), No.53 Mollasadra Avenue, P.O. Box 1991614661, Tehran, Iran; Unit 7, Marlin Park, Central Way, Feltham, Middlesex TW14 0XD, United Kingdom; Warehouse No.J-01, Dubai Airport Free Zone, Dubai, United Arab Emirates; P.O. Box 293020 Dubai Airport Free Zone, Dubai, United Arab Emirates; Cargo City South, Building 543, Frankfurt 60549, Germany; S.A. Pty Ltd Unit 8, the Meezricht Business Park, 33 Kelly Road, Jet Park, Boksburg North 1460, South Africa; Website http://www.dfsworldwide.com; Email Address irsales@dfsworldwide.com; DFS WORLWIDE, (a.k.a. DFS WORLDWIDE FZCO) is a separate and distinct entity from DFS Worldwide of Houston, Texas, USA and from Deutsche Financial Services, of Germany. [NPWMD] [IFSR].

ENERGY GLOBAL INTERNATIONAL FZE, P.O. Box 1245, Dubai, United Arab Emirates; Email Address MD@energyglobal.info [NPWMD] [IFSR].

EVEREX (a.k.a. EVEREX GLOBAL CARRIER AND CARGO; a.k.a. EVEREX LIMITED; a.k.a. SUN GROUP; a.k.a. SUN GROUP AIR TRAVEL AND AIR CARGO AND AIRPORT SERVICES LTD), Office 14, Cargo Terminal, Imam Khomeini International Airport, Tehran, Iran; 1267 Vali-E-Asr Avenue, Tehran, Iran; No.53 Mollasadra St, Vanak Square, Tehran, Iran; Office# J01, Dubai Airport Free Zone, Dubai, United Arab Emirates; P.O. Box 293020, Dubai, United Arab Emirates; Unit 7, Marlin Park, Central Way, Feltham TW14 OXD, United Kingdom; Website http://www.everexglobal.com; Email Address irsales@everexglobal.com; alt. Email Address uksales@everexglobal.com [NPWMD] [IFSR].

GLOBAL SEA LINE CO LTD, 10 Anson Road #31-10 International Plaza, Singapore; Email Address globalsealine@gmail.com [NPWMD] [IFSR].

PETRO GREEN (a.k.a. PETRO DIAMOND; a.k.a. PETROGREEN), B-8-1 Block B Megan Ave. II, 12 Jalan Yap Kwan Seng, Kuala Lumpur, Malaysia [NPWMD] [IFSR].

ZOLAL IRAN COMPANY, No. 2 Shariati Avenue, Niyam Street, Tehran, Iran [NPWMD] [IFSR].”

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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

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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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International criminal defense questions, but want to be anonymous?

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Specially Designated Narcotics Trafficking Kingpin [SDNTK] Entries Removed from OFAC’s SDN List on August 29, 2012

August 29, 2012

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

The following [SDNTK] entries have been removed:

AGROPECUARIA LA CRUZ S.A., Calle 137 No. 88-76 Int. 2 Apto. 143, Bogota, Colombia; NIT # 813004216-1 (Colombia) [SDNTK].

CRIADERO LAS CABANAS LTDA., Calle 137 No. 88-76 Int. 2 Apto. 143, Bogota, Colombia; NIT # 816005110-5 (Colombia) [SDNTK].

MARTINEZ GALINDO, Alicia (a.k.a. MARTINEZ, Alicia), c/o AMG RICAS PIZZA, Bogota, Colombia; DOB 26 Mar 1948; Cedula No. 41386662 (Colombia) (individual) [SDNTK].

MARTINEZ, Alicia (a.k.a. MARTINEZ GALINDO, Alicia), c/o AMG RICAS PIZZA, Bogota, Colombia; DOB 26 Mar 1948; Cedula No. 41386662 (Colombia) (individual) [SDNTK].

SARABIA DIAZ, Carlos Cristino, Calle Dalia No. 37, Colonia Aguaruto, Culiacan, Sinaloa, Mexico; c/o TOYS FACTORY, S.A. DE C.V., Tijuana, Baja California, Mexico; c/o COMERCIAL JOANA, S.A. DE C.V., Guadalajara, Jalisco, Mexico; c/o COMERCIALIZADORA BRIMAR’S, S.A. DE. C.V., Culiacan, Sinaloa, Mexico; c/o COMERCIAL DOMELY, S.A. DE C.V., Toluca, Mexico, Mexico; DOB 24 Jul 1971; POB Culiacan, Sinaloa, Mexico; nationality Mexico; citizen Mexico; R.F.C. SADC710724I71 (Mexico); C.U.R.P. SADC710724HSLRZR03 (Mexico) (individual) [SDNTK].

TARAZONA ENCISO, Nestor Alonso, c/o AGROPECUARIA LA CRUZ S.A., Bogota, Colombia; c/o CRIADERO LAS CABANAS LTDA., Bogota, Colombia; Calle 137 No. 52-37, Rincon Iberia, Bogota, Colombia; San Martin, Meta, Colombia; DOB 13 Jun 1965; Cedula No. 79344969 (Colombia) (individual) [SDNTK].

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

OFAC Litigation – SDN List Removal

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————————————————————–

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

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

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

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International criminal defense questions, but want to be anonymous?

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OFAC Introduces New SDN Data Production System

June 13, 2012

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) on June 13, 2012 released the following:

“OFAC has just launched a new, internal Specially Designated Nationals (SDN) and Blocked Persons List production system. This system is designed to emulate existing SDN data formats so that OFAC’s internal transition should be relatively transparent to the public. However, certain long-standing (but minor) problems with OFAC’s current data formats were corrected and users of the emulated SDN data will see some changes to records that are administrative only.

The following administrative changes have been made to SDN data in the emulated formats.

  1. All SDN data in the human-readable files now end in a period (.) . The period will serve as a true end of line marker from this point forward.
  2. Data that were produced with no specific ordering rules in the past now have ordering rules applied. For example, weak aliases in the remarks fields of the fixed-width and delimited files could change position within the remarks field from publication to publication. This will no longer occur. Specific ordering has also been applied to other data in the remarks (identification information like passport number, cedula number, etc. will appear in a consistent order from publication to publication).
  3. Extra/erroneous spaces that appeared in SDN records have been removed.
  4. Dates in the SDN data files could be published in variable formats. The following formats were allowed: D MMM YYYY; DD MMM YYYY; D MMM YY; DD MMM YY. Now all dates will be published in a single format DD MMM YYYY. Single digit days will now be padded with a 0 in front of the actual day.
  5. In the past OFAC used the abbreviation “c/o” in the address field of its data and human-readable files to describe a relationship between two or more SDNs. In the newly produced data files relationships between SDNs will be more clearly defined using the phrase, “Linked To:” as the following example shows.
  6. TEST COMPANY (a.k.a. BIG TEST COMPANY), Test Street 1, Test Street 2, Test Street 3, Test City, Test State Test Province, Test Country; Remarks Field test [IRAQ] Linked To: TEST, Joe.

    The “Linked To:” descriptor will start appearing in newly created SDNs. OFAC may replace older “c/o” records with “Linked To:” over time.

  7. Certain e-mail addresses in the OFAC data were associated with a specific country. That association has been removed.
  8. There was an inconsistency in the program codes presented in the human-readable SDN files as compared to the machine-readable files with regard to Zimbabwe. In the machine-readable SDN files the program code for Zimbabwe was ZIMB. In the human-readable files it was ZIMBABWE. The code is now ZIMBABWE in both sets of files.
  9. Dates of birth may now feature date ranges in place of “circa” values for new designations.
  10. Records in ADD.* files are now always ordered by ent_num and then by add_num. Records in ALT.* files are now always ordered by ent_num and then by alt_num.
  11. The SDN.XML file is now ordered by UID.

For the next few days the SDN data files that are produced by OFAC’s old SDN production system will be available in their current location. The new files will be available for download and testing. We STRONGLY encourage users of these data to download and review of the emulated SDN files. These files can be found here.

If you have any difficulty loading these new files into your screening systems, please contact OFAC immediately by e-mail at O_F_A_C@do.treas.gov. Please be as detailed as possible when describing your problem.”

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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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International criminal defense questions, but want to be anonymous?

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Specially Designated Global Terrorists [SDGT] Entries Added to OFAC’s SDN List on January 5, 2012

January 5, 2012

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

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

AL-QA’IDA KURDISH BATTALIONS (a.k.a. KURDISTAN BATTALION OF ISLAMIC STATE IN IRAQ; a.k.a. KURDISTAN BRIGADE OF ALQAEDA IN IRAQ; a.k.a. KURDISTAN
BRIGADES; a.k.a. “AQKB”), Iran; Iraq [SDGT]

AQKB (a.k.a. AL-QA’IDA KURDISH BATTALIONS; a.k.a. KURDISTAN BATTALION OF ISLAMIC STATE IN IRAQ; a.k.a. KURDISTAN BRIGADE OF AL-QAEDA IN IRAQ; a.k.a. KURDISTAN BRIGADES), Iran; Iraq [SDGT]

KURDISTAN BATTALION OF ISLAMIC STATE IN IRAQ (a.k.a. AL-QA’IDA KURDISH BATTALIONS; a.k.a. KURDISTAN BRIGADE OF AL-QAEDA IN IRAQ; a.k.a. KURDISTAN
BRIGADES; a.k.a. “AQKB”), Iran; Iraq [SDGT]

KURDISTAN BRIGADE OF AL-QAEDA IN IRAQ (a.k.a. AL-QA’IDA KURDISH BATTALIONS; a.k.a. KURDISTAN BATTALION OF ISLAMIC STATE IN IRAQ; a.k.a. KURDISTAN
BRIGADES; a.k.a. “AQKB”), Iran; Iraq [SDGT]

KURDISTAN BRIGADES (a.k.a. AL-QA’IDA KURDISH BATTALIONS; a.k.a. KURDISTAN BATTALION OF ISLAMIC STATE IN IRAQ; a.k.a. KURDISTAN BRIGADE OF AL-QAEDA IN IRAQ; a.k.a. “AQKB”), Iran; Iraq [SDGT]

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

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

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

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

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


Two-Thirds of Companies Report OFAC Sanctions Led to Renegotiated or Terminated Deals

February 7, 2011

According to results of Deloitte’s annual “Look Before You Leap” survey of corporate executives, investment bankers, private equity executives and hedge fund managers, 63 percent of respondents reported that Foreign Corrupt Practices Act (FCPA) and anti-corruption issues caused their companies to renegotiate or pull out of planned business relationships, mergers or acquisitions over the last three years.

Similarly, 62 percent of survey respondents pointed to issues related to potential violations of economic and trade sanctions, such as known or suspected dealings with Office of Foreign Assets Control (OFAC) sanctioned entities, as the cause for their companies to renegotiate or pull out of a deal over the past three years. The number of financial services industry respondents reporting economic and trade sanctions issues impacting a deal was higher at 64 percent.

Further data from the survey revealed that 21 percent of respondents identified a lack of transparency or unusual payment structures in contracts as reason for renegotiating or terminating deals, while 18 percent renegotiated or pulled out due to concerns regarding the target’s use of agents, consultants, distributors or third parties to obtain or facilitate business.

Clearly, the U.S. government is keeping a close eye on international financial dealings. However, the strict compliance standards regarding the FCPA and OFAC sanctions are causing significant hurdles for U.S. corporations and international business deals.

Due to the increase in renegotiated and terminated agreements, it could be argued U.S. restrictions are resulting in an overall detriment to U.S. business practices. Specifically, U.S. entities must ensure compliance with such regulations, otherwise they face civil and criminal consequences.

To review the survey in its entirety, please click here.

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

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

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Sanctions Placed on Belarus Leader

January 31, 2011

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

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

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

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

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

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

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

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

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

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Former Tunisian President on OFAC’s Radar

January 27, 2011

With the recent global alert issued by Interpol against former Tunisian President, Zine El Abidine Ben Ali may be facing an OFAC designation next.

Ben Ali and his family members are being sought for the illegal acquisition of assets and illicit transfers of funds abroad. These types of monetary transactions will most likely bring the former leader within OFAC’s radar.

OFAC specifically looks for illegal financial transactions in the international market. If OFAC believes the funds are related to illegal activity, it will not hesitate to place Ben Ali and his associates on the Specially Designated Nationals List (SDN List).

Ben Ali needs to realize that an OFAC designation may be near. The fact that authorities have already frozen assets belonging to Ben Ali’s family and his in-laws in Tunisia and in Switzerland is a red flag that OFAC is watching this situation closely.

If OFAC places Ben Ali on the SDN List, his assets relating to the U.S. will be frozen, and those under U.S. jurisdiction will be forbidden from engaging in any financial transaction with the former President. This may be significant to Ben Ali, particularly if he has assets in a U.S. foreign correspondent bank or in dealings with any entity with ties to the U.S.

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

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

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OFAC Adds Dead Man to SDN List?

January 24, 2011

The Office of Foreign Assets Control, located in Washington, D.C., has the power to place individuals and companies on the Specially Designated Nationals and Blocked Persons List. Once placement on the SDN List occurs, the assets of the individual or company are blocked, or “frozen.” Further, U.S. persons are prohibited from engaging in any trade or financial transaction with those on the SDN List.

Last Thursday, OFAC added Qari Hussain (also known as Qari Hussain Mehsud) to the SDN List. However, according to this report, Hussain was killed by a U.S. drone in North Waziristan on October 4, 2010.

In the past, it was mistakenly reported that Hussain was killed, but Hussain made sure to call the local media and publicize that he was still alive. Since October of last year, no efforts have been made to counter the reports of his death.

The evidence of Hussain’s death is reasonable, so why would OFAC place him on the SDN List? This is just another instance of OFAC acting without investigating the facts. Hussain’s untimely designation on the SDN List demonstrates the inefficient practices of OFAC and conveys the fact that OFAC takes an all or nothing approach in their designations.

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

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

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