Muammar Gadhafi Placed on OFAC SDN List; $30 Billion Located and Frozen

February 28, 2011

Last Friday, the White House announced Muammar Gadhafi has been placed on the OFAC SDN List. As of today, OFAC has located and frozen at least $30 billion in Libyan assets as it seeks to deprive leader Muammar Gadhafi of access to government and personal accounts.

President Obama singed into effect an Executive Order blocking property and prohibiting certain transactions related to Libya. The E.O. targets Gadhafi, senior government officials, Gadhafi’s children, material supporters of the Government of Libya and the Central Bank of Libya.

Over the weekend, the United Nations unanimously approved a resolution sanctioning Libya, and the U.K. announced its own measures following the U.N. guidelines. Monday morning, the European Union announced its own measures that extended the U.N. sanctions to 20 additional individuals.

The U.S. and international sanctions are a direct financial attack against Gadhafi and his supporters, clearly indicating the concern regarding the current regime and the effort to sever Gadhafi from his financial assets.

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

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

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Will OFAC Freeze Mubarak’s U.S. Assets?

February 17, 2011

The Egyptian government has requested that the U.S. Treasury Department seize the assets of a number of Egyptian individuals, though so far that list does not include former President Hosni Mubarak.

The request was made over the weekend, however the names of the Egyptian nationals the new government in Cairo is targeting have not been released.

The governments of Germany, France and the U.K. said they received a request from Egyptian authorities to freeze the assets of former senior officials. European Union finance ministers discussed the issue at a meeting in Brussels earlier this week.

Within hours of Mubarak’s resignation, the Swiss announced their intention to find and freeze any assets believed to be in the hands of Mubarak or his inner circle. British Foreign Secretary William Hague told Parliament the U.K. would cooperate with Egypt’s request, and French Finance Minister Christine Lagarde pledged assistance as well.

The moves come amid an international effort to track down assets linked to the ousted president of Tunisia, Zine al-Abidine Ben Ali, who fled to Saudi Arabia on January 14. The European Union and the Swiss have moved to freeze assets belonging to the former leader, his wife and dozens of associates and relatives. French authorities opened their own investigation of his property, spurred by legal complaints filed by anti-corruption organizations.

The FBI is looking at whether Ben Ali has assets in the U.S. or has used U.S. financial institutions to move illicit funds. An official at the Tunisian embassy in Washington has said the interim government requested that the U.S. freeze assets belonging to Ben Ali and his family. The request was sent last month, the official said.

Although Mubarak has not been designated by OFAC, the Swiss government has already expressed their intention to find and freeze any assets believed to be in the hands of Mubarak or his inner circle. Further, the U.K. has vowed to freeze any of Mubarak’s assets upon proof of illegality. Surely OFAC is watching this situation closely, and an investigation into Mubarak’s U.S. assets is most likely underway.

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

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

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OFAC’s Power Extends to Vessels on the High Seas

February 17, 2011

The Office of Foreign Assets Control (OFAC) is issuing General License No. 3 under the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. Part 544, authorizing certain transactions related to the arrest, detention and judicial sale of the MV First Ocean and the MV Second Ocean, which are two vessels on OFAC’s Specially Designated Nationals and Blocked Persons list.

These vessels are currently under arrest in Chiwan and Qingdao, the People’s Republic of China, respectively. The general license allows for the purchase and acquisition of the vessels, as well as guidance for expedited SDN removal.

As this case demonstrates, in addition to individuals and entities, OFAC has the authority to place vessels on the SDN List as part of it’s broad sanctions power.

For a complete reading of the license, which provides insight into OFAC’s requirements for SDN removal, please click here.

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

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

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

February 10, 2011

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

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

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

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

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

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

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

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

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