“US planned to sanction disbanded border security force, say activists”

July 23, 2013

Myanmar Times on July 22, 2013 released the following:

“By Bill O’Toole

Human rights groups say a controversial border security force that was disbanded last week was about to be sanctioned by the United States Treasury.

The decision to abolish the force, which is widely referred to as Na Sa Ka and has been accused of human rights abuses, was announced by the President’s Office in a statement on July 14. “It is hereby announced that Border Area Immigration Control Headquarters has been abolished,” the statement said, referring to the group by its official name.

The statement gave no reason for the decision and presidential spokesperson U Ye Htut declined requests for comment.

But human rights groups based both in and outside Myanmar have told The Myanmar Times that US sanctions against the security force were “imminent” and the decision to abolish the force was likely taken to stop the sanctions from being put in place.

“There were plans afoot in Washington to list the Na Sa Ka on the [Specially Designated Nationals] list maintained by the US Department of the Treasury,” said Phil Robertson, the Bangkok-based Asia director for Human Rights Watch.

“A decision on that was imminent and obviously Burmese leaders in Nay Pyi Taw learned about this and decided to cut their losses by scrapping the unit,” he said, adding that he had been told this by people “in the know” in Washington.

Matt Smith of Fortify Rights International said he was not absolutely certain what the US was planning but agreed that “Na Sa Ka was being looked at closely by the US Treasury due to its abusive record, and was on the verge of being sanctioned”.

“This and other factors undoubtedly influenced Thein Sein’s decision,” he said.

A spokesperson for the Department of Treasury said he could not comment on possible Treasury actions.

Andrew Leahy, a public affairs officer at the US embassy in Yangon, also declined to comment on Treasury operations.

He did say, however, that “sanctions are certainly designed to hold people accountable. The reason they’re in place is to target people who hinder the reform process.”

The allegations raise the question of how the President’s Office learned of the planned sanctions.

In Washington, however, activists say the impending sanctions were relatively common knowledge. In February, rights groups pushed for the sanctioning of controversial government bodies like Na Sa Ka at a Congressional hearing on Myanmar.

“We know this was the discussion because we’ve been pushing sanctions for the Na Sa Ka and regional commanders [to the US Treasury Department],” said Jennifer Quigley, the Washington-based executive director of US Campaign for Burma.

As the recent decision to sanction Lieutenant General Thein Htay for his involvement in arms deals with North Korea shows, the US is more than willing to add new entities to its targeted SDN list even as it allows US companies to invest in and trade with Myanmar.

Na Sa Ka was a unique organisation that brought together officials from the departments of immigration and customs, as well as members of the military.

Its mandate was limited to securing the border with Bangladesh in northern Rakhine State.

Over the past year and a half, the 1200-strong force was implicated in communal violence in Rakhine State, particularly the persecution and exploitation of the Muslim Rohingya, who are commonly referred to as Bengalis in Myanmar.

Ms Quigley described Na Sa Ka as the most “violent and corrupt” armed body in Myanmar.

While sanctions against specific commanders are still possible under US law, several sources said they were concerned that the move to abolish the force would protect the Na Sa Ka from investigation for the alleged rights violations.

“U Thein Sein’s decision was based on … trying to short-circuit investigations of what the Na Sa Ka has done” and limiting public relations damage before his European trip, Mr Robertson said.

The 1200 members of Na Sa Ka have returned to their original organisations and a battalion of police have assumed the group’s duties along the border and at various checkpoints in northern Rakhine State.

It is not clear if the police will permanently take on this role and rights advocates expressed scepticism that the decision to abolish Na Sa Ka would lead to any improvements in the human rights situation in northern Rakhine State.

“In the absence of accountability, there is nothing to prevent the next security force from simply replicating Na Sa Ka’s abusive ways,” Mr Smith said.

Sittwe resident U Aung Win said he had not heard any reports of the police battalion engaging in the exploitation that Na Sa Ka was notorious for.

He said the most people were “very happy” to see Na Sa Ka disbanded, regardless of the motives behind the decision.”

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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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“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

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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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“Colombian Soccer Team Removed From U.S. Treasury’s Drug List”

April 4, 2013

Fox News Latino on April 3, 2013 released the following:

“Lance Armstrong and Barry Bonds have got nothing on Colombia’s America de Cali soccer team.

EPO and human growth hormones are child’s play compared to the Cali squad, which has been on the United State’s list of Specially Designated Nationals and Blocked Persons (SDN List) since 1999, after the U.S. claimed the team was under the ownership of Cali drug cartel leaders Miguel and Gilberto Rodriguez Orejuela.

While Toronto Blue Jays’ outfielder Melky Cabrera’s suspension and redemption only lasted 50 games, America de Cali had to wait 14 seasons for their chance, as the U.S. Treasury Department finally removed Wednesday the team from SDN list.

“Today’s lifting of the designation of America de Cali is a testament to the enormous efforts made in recent years by both the team and the Colombian government to completely break with the criminal influences that have overshadowed the team in the past,” said David S. Cohen, Under Secretary for Terrorism and Financial Intelligence, in a press statement.

America de Cali’s front office recently underwent an enormous restructuring and bankruptcy deal, with oversight from the Colombian government to monitor that the team had cut all ties with the former drug lords.

Both Rodríguez Orejuela brothers were arrested and then extradited to the U.S. in 2006, where they pleaded guilty in Miami to charges of conspiracy to import cocaine into the United States.

During the 1980s and 1990s, Colombian drug cartels became deeply involved in the country’s professional soccer league. Besides America de Cali, Medellín’s Atlético Nacional was heavily supported, both financially and on a fan basis, by famed cartel leader Pablo Escobar.

The Medellín Cartel and the Cali Cartel used the teams in a sometimes friendly, sometimes not-so-friendly rivalry between the two groups of narcos.

Besides the removal of the team from the SDN list, the Treasury Department praised the work of the Colombian government and promised to continue working with the Latin American nation to thwart drug cartels.

“As we continue our work with the Colombian government to combat the threat of narcotics trafficking, we will use our authorities to target those responsible for illicit behavior just as we will lift sanctions in cases where there has been a concrete change in behavior,” Cohen said.”

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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 New Sanctions On Iran Proliferators, Companies Linked To Regime

July 17, 2012

RTT News on July 12, 2012 released the following:

“(RTTNews) – The U.S. Treasury Department announced Thursday it is sanctioning a number of companies and individuals tied to weapons proliferation in Iran or circumvention of existing sanctions on the Iranian regime.

“Iran today is under intense, multilateral sanctions pressure, and we will continue to ratchet up the pressure so long as Iran refuses to address the international community’s well-founded concerns about its nuclear program,” Treasury Under Secretary for Terrorism and Financial Intelligence David S. Cohen said in a press release.

He added, “Today’s actions are our next step on that path, taking direct aim at disrupting Iran’s nuclear and ballistic missile programs as well as its deceptive efforts to use front companies to sell and move its oil.”

Today’s new sanctions came in two parts: 1) placing sanctions on 15 entities or individuals involved in supporting Iran’s nuclear and ballistic missile programs and 2) publicly sanctioning over 25 companies and individuals as Specially Designated Nationals (SDN) who have repeatedly acted to circumvent current sanctions on the Iranian regime.

Both sets of sanctions block all U.S. persons and companies from engaging in any transactions with the designated entities and individuals.

Most of the entities designated under the first set of sanctions (E.O. 13382) are tied to Iran’s Ministry of Defense for Armed Forces Logistics (MODAFL) and its subsidiary Aerospace Industries Organization (AIO).

Under executive order 13382, which is “aimed at freezing the assets of proliferators of weapons of mass destruction and their supporters and isolating them financially,” Treasury can prohibit all transactions between the designees and any U.S. person and freeze any assets the designees may have under U.S. jurisdiction, according to the State Department.

Electronic Components Industries Co. (ECI) and Information Systems Iran (ISIRAN), one of the largest and most experienced information technology companies in Iran, and Daniel Frosch, an Austrian exporter currently living in Dubai, were both designated under E.O. 13382. Frosch had previously been under investigation by Austria for exporting components that could be used in nuclear weapons to Iran.

The second set of sanctions, pursuant under E.O. 13599 or the SDN List, targets “individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific,” according to Treasury.

Petro Suisse Intertrade Company SA (Switzerland), Hong Kong Intertrade Company, Noor Energy Ltd, (Malaysia) and Petro Energy Intertrade Company (Dubai) were all added to the SDN List today “because they are owned or controlled by, or acting for or on behalf of, the Government of Iran,” Treasury said.

Twenty Iranian financial institutions were also designated as SDN as well as 58 National Iranian Tanker Company (NITC) vessels, the NITC itself and 27 of its affiliated entities.

Pundits have argued over the efficiency of the U.S. government’s two-track approach to Iran – on the one hand, pressuring the regime with sanctions and on the other, urging them to discuss their nuclear program during meetings with the international community.

However, recent leaks from Iran showing state-owned news agencies being discouraged from reporting the effects of sanctions could show the steps are having an impact.

“Our country is not in a position to allow the media to publish news or analysis which is not compatible with the regime’s and national interests,” Ministry of Culture and Islamic Guidance chief Mohammad Hosseini recently told local media site dolat.ir in uncharacteristically candid terms.

He added, “The situation regarding sanctions and other pressures, especially in economy … requires more cooperation by the media so the country is not hurt.”

The next round of working-level meetings between Iran and the P5+1, the international group charged with discussing the Iranian nuclear program, will take place in Istanbul on July 24th.

by RTT Staff Writer”

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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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[IRAN] [IFSR] [NPWMD] Entries Changed and Added, and [IRAN] Entries Added to OFAC’s SDN List on July 12, 2012

July 15, 2012

On July 12, 2012, OFAC has added and changed [IRAN] [IFSR] [NPWMD] Entries and added [IRAN] Entries to the Specially Designated Nationals List (SDN List):

The following [IRAN] [IFSR] [NPWMD] entries have been changed:

ANSAR BANK (a.k.a. ANSAR FINANCE AND CREDIT FUND; a.k.a. ANSAR FINANCIAL AND CREDIT INSTITUTE; f.k.a. “ANSAR ALMOJAHEDIN NO-INTEREST LOAN INSTITUTE”; f.k.a. “ANSAR INSTITUTE”; f.k.a. “ANSAR SAVING AND INTEREST FREELOANS FUND”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran [NPWMD] [IFSR]. -to- ANSAR BANK (a.k.a. ANSAR FINANCE AND CREDIT FUND; a.k.a. ANSAR FINANCIAL AND CREDIT INSTITUTE; a.k.a. BANK-E ANSAR; f.k.a. “ANSAR ALMOJAHEDIN NO-INTEREST LOAN INSTITUTE”; f.k.a. “ANSAR INSTITUTE”; f.k.a. “ANSAR SAVING AND INTEREST FREELOANS FUND”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran; North Pasdaran St., No. 539, Before Sahebgharanieh, corner of Narenjestan dahom, Tehran, Iran[IRAN] [NPWMD] [IFSR].

ANSAR FINANCE AND CREDIT FUND (a.k.a. ANSAR BANK; a.k.a. ANSAR FINANCIAL AND CREDIT INSTITUTE; f.k.a. “ANSAR LMOJAHEDIN NO-INTEREST LOAN INSTITUTE”; f.k.a. “ANSAR INSTITUTE”; f.k.a. “ANSAR SAVING AND INTEREST FREELOANS FUND”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran [NPWMD] [IFSR]. -to- ANSAR FINANCE AND CREDIT FUND (a.k.a. ANSAR BANK; a.k.a. ANSAR FINANCIAL AND CREDIT INSTITUTE; a.k.a. BANK-E ANSAR; f.k.a. “ANSAR ALMOJAHEDIN NO-INTEREST LOAN INSTITUTE”; f.k.a. “ANSAR INSTITUTE”; f.k.a. “ANSAR SAVING AND INTEREST FREELOANS FUND”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran; North Pasdaran St., No. 539, Before Sahebgharanieh, corner of Narenjestan dahom, Tehran, Iran[IRAN] [NPWMD] [IFSR].

ANSAR FINANCIAL AND CREDIT INSTITUTE (a.k.a. ANSAR BANK; a.k.a. ANSAR FINANCE AND CREDIT FUND; f.k.a. “ANSAR ALMOJAHEDIN NO-INTEREST LOAN INSTITUTE”; f.k.a. “ANSAR INSTITUTE”; f.k.a. “ANSAR SAVING AND INTEREST FREELOANS FUND”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran [NPWMD] [IFSR]. -to- ANSAR FINANCIAL AND CREDIT INSTITUTE (a.k.a. ANSAR BANK; a.k.a. ANSAR FINANCE AND CREDIT FUND; a.k.a. BANK-E ANSAR; f.k.a. “ANSAR ALMOJAHEDIN NO-INTEREST LOAN INSTITUTE”; f.k.a. “ANSAR INSTITUTE”; f.k.a. “ANSAR SAVING AND INTEREST FREELOANS FUND”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran; North Pasdaran St., No. 539, Before Sahebgharanieh, corner of Narenjestan dahom, Tehran, Iran[IRAN] [NPWMD] [IFSR].

FUTURE BANK B.S.C., P.O. Box 785, City Centre Building, Government Avenue, Manama, Bahrain; Block 304, City Centre Building, Building 199, Government Avenue, Road 383, Manama, Bahrain; Business Registration Document # 54514-1 (Bahrain) expires 09 Jun 2009; Trade License No. 13388 (Bahrain); All branches worldwide [NPWMD] [IFSR]. -to- FUTURE BANK B.S.C. (a.k.a. BANK-E ALMOSTAGHBAL; a.k.a. FUTURE BANK), P.O. Box 785, City Centre Building, Government Avenue, Manama, Bahrain; Block 304, City Centre Building, Building 199, Government Avenue, Road 383, Manama, Bahrain; Free Trade Zone, Sanaati-e Kish, Vilay-e Ferdos 2, Corner of Klinik-e Khanevadeh, No 1/5 and 3/5, Kish, Iran; Business Registration Document # 54514-1 (Bahrain) expires 09 Jun 2009; Trade License No. 13388 (Bahrain); All branches worldwide[IRAN] [NPWMD] [IFSR].

POST BANK OF IRAN, 237 Motahari Avenue, Tehran 1587618118, Iran [NPWMD] [IFSR]. -to- POST BANK OF IRAN (a.k.a. SHERKAT-E DOLATI-E POST BANK; a.k.a. “PBI”), 237 Motahari Avenue, Tehran 1587618118, Iran; Motahari Street, No. 237, Past Darya-e Noor, Tehran, Iran[IRAN] [NPWMD] [IFSR].

“ANSAR AL-MOJAHEDIN NO-INTEREST LOAN INSTITUTE” (a.k.a. ANSAR BANK; a.k.a. ANSAR FINANCE AND CREDIT FUND; a.k.a. ANSAR FINANCIAL AND CREDIT INSTITUTE; f.k.a. “ANSAR INSTITUTE”; f.k.a. “ANSAR SAVING AND INTEREST FREE-LOANS FUND”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran [NPWMD] [IFSR]. -to- “ANSAR AL-MOJAHEDIN NOINTEREST LOAN INSTITUTE” (a.k.a. ANSAR BANK; a.k.a. ANSAR FINANCE AND CREDIT FUND; a.k.a. ANSAR FINANCIAL AND CREDIT INSTITUTE; a.k.a. BANK-E ANSAR; f.k.a. “ANSAR INSTITUTE”; f.k.a. “ANSAR SAVING AND INTEREST FREE-LOANS FUND”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran; North Pasdaran St., No. 539, Before Sahebgharanieh, corner of Narenjestan dahom, Tehran, Iran[IRAN] [NPWMD] [IFSR].

“ANSAR INSTITUTE” (a.k.a. ANSAR BANK; a.k.a. ANSAR FINANCE AND CREDIT FUND; a.k.a. ANSAR FINANCIAL AND CREDIT INSTITUTE; f.k.a. “ANSAR AL-MOJAHEDIN NO-INTEREST LOAN INSTITUTE”; f.k.a. “ANSAR SAVING AND INTEREST FREELOANS FUND”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran [NPWMD] [IFSR]. -to- “ANSAR INSTITUTE” (a.k.a. ANSAR BANK; a.k.a. ANSAR FINANCE AND CREDIT FUND; a.k.a. ANSAR FINANCIAL AND CREDIT INSTITUTE; a.k.a. BANK-E ANSAR; f.k.a. “ANSAR ALMOJAHEDIN NO-INTEREST LOAN INSTITUTE”; f.k.a. “ANSAR SAVING AND INTEREST FREE-LOANS FUND”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran; North Pasdaran St., No. 539, Before Sahebgharanieh, corner of Narenjestan dahom, Tehran, Iran[IRAN] [NPWMD] [IFSR].

“ANSAR SAVING AND INTEREST FREE-LOANS FUND” (a.k.a. ANSAR BANK; a.k.a. ANSAR FINANCE AND CREDIT FUND; a.k.a. ANSAR FINANCIAL AND CREDIT INSTITUTE; f.k.a. “ANSAR AL-MOJAHEDIN NO-INTEREST LOAN INSTITUTE”; f.k.a. “ANSAR INSTITUTE”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran [NPWMD] [IFSR]. -to- “ANSAR SAVING AND INTEREST FREE-LOANS FUND” (a.k.a. ANSAR BANK; a.k.a. ANSAR FINANCE AND CREDIT FUND; a.k.a. ANSAR FINANCIAL AND CREDIT INSTITUTE; a.k.a. BANK-E ANSAR; f.k.a. “ANSAR ALMOJAHEDIN NO-INTEREST LOAN INSTITUTE”; f.k.a. “ANSAR INSTITUTE”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran; North Pasdaran St., No. 539, Before Sahebgharanieh, corner of Narenjestan dahom, Tehran, Iran[IRAN] [NPWMD] [IFSR].

resulting in the following new [IRAN] [IFSR] [NPWMD] entries:

BANK-E AL-MOSTAGHBAL (a.k.a. FUTURE BANK; a.k.a. FUTURE BANK B.S.C.), P.O. Box 785, City Centre Building, Government Avenue, Manama, Bahrain; Block 304, City Centre Building, Building 199, Government Avenue, Road 383, Manama, Bahrain; Free Trade Zone, Sanaati-e Kish, Vilay-e Ferdos 2, Corner of Klinik-e Khanevadeh, No 1/5 and 3/5, Kish, Iran; Business Registration Document # 54514-1 (Bahrain) expires 09 Jun 2009; Trade License No. 13388 (Bahrain); All branches worldwide [IRAN] [NPWMD] [IFSR].

BANK-E ANSAR (a.k.a. ANSAR BANK; a.k.a. ANSAR FINANCE AND CREDIT FUND; a.k.a. ANSAR FINANCIAL AND CREDIT INSTITUTE; f.k.a. “ANSAR AL-MOJAHEDIN NO-INTEREST LOAN INSTITUTE”; f.k.a. “ANSAR INSTITUTE”; f.k.a. “ANSAR SAVING AND INTEREST FREELOANS FUND”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran; North Pasdaran St., No. 539, Before Sahebgharanieh, corner of Narenjestan dahom, Tehran, Iran [IRAN] [NPWMD] [IFSR].

FUTURE BANK (a.k.a. BANK-E ALMOSTAGHBAL; a.k.a. FUTURE BANK B.S.C.), P.O. Box 785, City Centre Building, Government Avenue, Manama, Bahrain; Block 304, City Centre Building, Building 199, Government Avenue, Road 383, Manama, Bahrain; Free Trade Zone, Sanaati-e Kish, Vilay-e Ferdos 2, Corner of Klinik-e Khanevadeh, No 1/5 and 3/5, Kish, Iran; Business Registration Document # 54514-1 (Bahrain) expires 09 Jun 2009; Trade License No. 13388 (Bahrain); All branches worldwide [IRAN] [NPWMD] [IFSR].

SHERKAT-E DOLATI-E POST BANK (a.k.a. POST BANK OF IRAN; a.k.a. “PBI”), 237 Motahari Avenue, Tehran 1587618118, Iran; Motahari Street, No. 237, Past Darya-e Noor, Tehran, Iran [IRAN] [NPWMD] [IFSR].

“PBI” (a.k.a. POST BANK OF IRAN; a.k.a. SHERKAT-E DOLATI-E POST BANK), 237 Motahari Avenue, Tehran 1587618118, Iran; Motahari Street, No. 237, Past Darya-e Noor, Tehran, Iran [IRAN] [NPWMD] [IFSR].

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

BANK MOSHTAREK-E IRAN VENEZUELA (a.k.a. JOINT IRAN-VENEZUELA BANK), Ahmad Ghasir St. (Bokharest), Corner of 15th St., Tose Tower, No.44-46, Tehran 1013830711, Iran [IRAN].

BANK-E DEY (a.k.a. DEY BANK), Bokharest St., 1st St., No. 13, Tehran, Iran [IRAN].

BANK-E EGHTESAD NOVIN (a.k.a. EGHTESAD NOVIN BANK; a.k.a. EN BANK PJSC), Vali Asr Street, Above Vanak Circle, across Niayesh, Esfandiari Blvd., No. 24, Tehran, Iran; SWIFT/BIC BEGN IR TH [IRAN].

BANK-E GARDESHGARI (a.k.a. TOURISM BANK), Vali Asr St., above Vey Park, Shahid Fiazi St., No. 51, first floor, Tehran, Iran [IRAN].

BANK-E GHARZOLHASANEH MEHR IRAN (a.k.a. GHARZOLHASANEH MEHR IRAN BANK; a.k.a. MEHR IRAN CREDIT UNION BANK), Taleghani St., No.204, Before the intersection of Mofateh, across from the former U.S. embassy, Tehran, Iran [IRAN].

BANK-E HEKMAT IRANIAN (a.k.a. HEKMAT IRANIAN BANK), Argentine Circle, beginning of Africa St., Corner of 37th St., (Dara Cul-de-sac), No.26, Tehran, Iran [IRAN].

BANK-E IRAN ZAMIN (a.k.a. IRAN ZAMIN BANK), Seyyed Jamal-oldin Asadabadi St., Corner of 68th St., No. 472, Tehran, Iran [IRAN].

BANK-E KARAFARIN (a.k.a. KARAFARIN BANK), Zafar St. No. 315, Between Vali Asr and Jordan, Tehran, Iran; SWIFT/BIC KBID IR TH [IRAN].

BANK-E PARSIAN (a.k.a. PARSIAN BANK), Keshavarz Blvd., No. 65, Corner of Shahid Daemi St., P.O. Box 141553163, Tehran 1415983111, Iran; No. 4 Zarafshan St, Farahzadi Blvd, Shahrak-e Ghods, 1467793811, Tehran, Iran; SWIFT/BIC BKPA IR TH [IRAN].

BANK-E PASARGAD (a.k.a. PASARGAD BANK), Valiasr St., Mirdamad St., No. 430, Tehran, Iran; SWIFT/BIC BKBP IR TH [IRAN].

BANK-E SAMAN (a.k.a. SAMAN BANK), Vali Asr. St. No. 3, Before Vey Park intersection, corner of Tarakesh Dooz St., Tehran, Iran; SWIFT/BIC SABC IR TH [IRAN].

BANK-E SARMAYEH (a.k.a. SARMAYEH BANK), Sepahod Gharani No. 24, Corner of Arak St., Tehran, Iran [IRAN].

BANK-E SHAHR, Sepahod Gharani, Corner of Khosro St., No. 147, Tehran, Iran [IRAN].

BANK-E TAAWON MANTAGHEEY-E ESLAMI (a.k.a. ISLAMIC REGIONAL COOPERATION BANK; a.k.a. REGIONAL COOPERATION OF THE ISLAMIC BANK FOR DEVELOPMENT & INVESTMENT), Building No. 59, District 929, Street No. 17, Arsat Al-Hindia, Al Masbah, Baghdad, Iraq; Tohid Street, Before Tohid Circle, No. 33, Upper Level of Eghtesad-e Novin Bank, Tehran 1419913464, Iran; SWIFT/BIC RCDF IQ BA [IRAN].

BANK-E TAT (a.k.a. TAT BANK), Shahid Ahmad Ghasir (Bocharest), Shahid Ahmadian (15th) St., No. 1, Tehran, Iran; No. 1 Ahmadian Street, Bokharest Avenue, Tehran, Iran; SWIFT/BIC TATB IR TH [IRAN].

BANK-E TOSE’E TA’AVON (a.k.a. COOPERATIVE DEVELOPMENT BANK; a.k.a. TOSEE TAAVON BANK), Mirdamad Blvd., North East Corner of Mirdamad Bridge, No. 271, Tehran, Iran [IRAN].

COOPERATIVE DEVELOPMENT BANK (a.k.a. BANK-E TOSE’E TA’AVON; a.k.a. TOSEE TAAVON BANK), Mirdamad Blvd., North East Corner of Mirdamad Bridge, No. 271, Tehran, Iran [IRAN].

CREDIT INSTITUTION FOR DEVELOPMENT, 53 Saanee, Jahan-e Koodak, Crossroads Africa St., Tehran, Iran [IRAN].

DEY BANK (a.k.a. BANK-E DEY), Bokharest St., 1st St., No. 13, Tehran, Iran [IRAN].

EGHTESAD NOVIN BANK (a.k.a. BANK-E EGHTESAD NOVIN; a.k.a. EN BANK PJSC), Vali Asr Street, Above Vanak Circle, across Niayesh, Esfandiari Blvd., No. 24, Tehran, Iran; SWIFT/BIC BEGN IR TH [IRAN].

EN BANK PJSC (a.k.a. BANK-E EGHTESAD NOVIN; a.k.a. EGHTESAD NOVIN BANK), Vali Asr Street, Above Vanak Circle, across Niayesh, Esfandiari Blvd., No. 24, Tehran, Iran; SWIFT/BIC BEGN IR TH [IRAN].

GHARZOLHASANEH MEHR IRAN BANK (a.k.a. BANK-E GHARZOLHASANEH MEHR IRAN; a.k.a. MEHR IRAN CREDIT UNION BANK), Taleghani St., No.204, Before the intersection of Mofateh, across from the former U.S. embassy, Tehran, Iran [IRAN].

HEKMAT IRANIAN BANK (a.k.a. BANK-E HEKMAT IRANIAN), Argentine Circle, beginning of Africa St., Corner of 37th St., (Dara Cul-desac), No.26, Tehran, Iran [IRAN].

IRAN ZAMIN BANK (a.k.a. BANK-E IRAN ZAMIN), Seyyed Jamal-oldin Asadabadi St., Corner of 68th St., No. 472, Tehran, Iran [IRAN].

ISLAMIC REGIONAL COOPERATION BANK (a.k.a. BANK-E TAAWON MANTAGHEEY-E ESLAMI; a.k.a. REGIONAL COOPERATION OF THE ISLAMIC BANK FOR DEVELOPMENT & INVESTMENT), Building No. 59, District 929, Street No. 17, Arsat Al-Hindia, Al Masbah, Baghdad, Iraq; Tohid Street, Before Tohid Circle, No. 33, Upper Level of Eghtesad-e Novin Bank, Tehran 1419913464, Iran; SWIFT/BIC RCDF IQ BA [IRAN].

JOINT IRAN-VENEZUELA BANK (a.k.a. BANK MOSHTAREK-E IRAN VENEZUELA), Ahmad Ghasir St. (Bokharest), Corner of 15th St., Tose Tower, No.44-46, Tehran 1013830711, Iran [IRAN].

KARAFARIN BANK (a.k.a. BANK-E KARAFARIN), Zafar St. No. 315, Between Vali Asr and Jordan, Tehran, Iran; SWIFT/BIC KBID IR TH [IRAN].

MEHR IRAN CREDIT UNION BANK (a.k.a. BANK-E GHARZOLHASANEH MEHR IRAN; a.k.a. GHARZOLHASANEH MEHR IRAN BANK), Taleghani St., No.204, Before the intersection of Mofateh, across from the former U.S. embassy, Tehran, Iran [IRAN].

PARSIAN BANK (a.k.a. BANK-E PARSIAN), Keshavarz Blvd., No. 65, Corner of Shahid Daemi St., P.O. Box 141553163, Tehran 1415983111, Iran; No. 4 Zarafshan St, Farahzadi Blvd, Shahrak-e Ghods, 1467793811, Tehran, Iran; SWIFT/BIC BKPA IR TH [IRAN].

PASARGAD BANK (a.k.a. BANK-E PASARGAD), Valiasr St., Mirdamad St., No. 430, Tehran, Iran; SWIFT/BIC BKBP IR TH [IRAN].

REGIONAL COOPERATION OF THE ISLAMIC BANK FOR DEVELOPMENT & INVESTMENT (a.k.a. BANK-E TAAWON MANTAGHEEY-E ESLAMI; a.k.a. ISLAMIC REGIONAL COOPERATION BANK), Building No. 59, District 929, Street No. 17, Arsat Al-Hindia, Al Masbah, Baghdad, Iraq; Tohid Street, Before Tohid Circle, No. 33, Upper Level of Eghtesad-e Novin Bank, Tehran 1419913464, Iran; SWIFT/BIC RCDF IQ BA [IRAN].

SAMAN BANK (a.k.a. BANK-E SAMAN), Vali Asr. St. No. 3, Before Vey Park intersection, corner of Tarakesh Dooz St., Tehran, Iran; SWIFT/BIC SABC IR TH [IRAN].

SARMAYEH BANK (a.k.a. BANK-E SARMAYEH), Sepahod Gharani No. 24, Corner of Arak St., Tehran, Iran [IRAN].

TAT BANK (a.k.a. BANK-E TAT), Shahid Ahmad Ghasir (Bocharest), Shahid Ahmadian (15th) St., No. 1, Tehran, Iran; No. 1 Ahmadian Street, Bokharest Avenue, Tehran, Iran; SWIFT/BIC TATB IR TH [IRAN].

TOSEE TAAVON BANK (a.k.a. BANK-E TOSE’E TA’AVON; a.k.a. COOPERATIVE DEVELOPMENT BANK), Mirdamad Blvd., North East Corner of Mirdamad Bridge, No. 271, Tehran, Iran [IRAN].

TOURISM BANK (a.k.a. BANK-E GARDESHGARI), Vali Asr St., above Vey Park, Shahid Fiazi St., No. 51, first floor, Tehran, Iran [IRAN].

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United States Increases Sanctions Against The Government Of Iran And Its Proliferation Networks

7/12/2012
Treasury and State Department Actions Target More Than 50 Entities

Tied to Iran’s Procurement, Petroleum, and Shipping Networks

WASHINGTON – Today, the United States is imposing additional sanctions on Iran’s nuclear and ballistic missile proliferation networks, and is also taking additional steps to prevent the evasion of sanctions by publicly identifying a group of Iranian front companies and banks. These actions are part of the United States government’s dual-track approach of increasing pressure to convince Iran to engage seriously and address the international community’s concerns about its nuclear program.

“Iran today is under intense, multilateral sanctions pressure, and we will continue to ratchet up the pressure so long as Iran refuses to address the international community’s well-founded concerns about its nuclear program,” said Treasury Under Secretary for Terrorism and Financial Intelligence David S. Cohen. “Today’s actions are our next step on that path, taking direct aim at disrupting Iran’s nuclear and ballistic missile programs as well as its deceptive efforts to use front companies to sell and move its oil.”

Targeting Iran’s Nuclear and Missile Proliferation Activities

Since 2005, the United States has imposed a series of targeted, conduct-based sanctions under Executive Order (E.O.) 13382, “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters,” on persons, firms and financial institutions involved in Iran’s nuclear and ballistic missile programs. This sustained sanctions effort has both disrupted the progress of Iran’s nuclear and ballistic missile program and imposed significant pressure on the Iranian government.

Continuing the effort to target Iran’s nuclear and missile proliferation activities, the U.S. Departments of the Treasury and State are today designating 11 entities and four individuals under E.O. 13382. As described in more detail in the accompanying Fact Sheet, many of the individuals and entities designated today are part of a network of proliferators headed by Iran’s Ministry of Defense for Armed Forces Logistics (MODAFL) and its subsidiary, Aerospace Industries Organization (AIO). A number of additional designations are related to Iran’s national maritime carrier, Islamic Republic of Iran Shipping Lines (IRISL), and Iran’s Islamic Revolutionary Guard Corps (IRGC), both of which have been the target of a numerous sanctions actions by the United States and our partners around the world.

Preventing the Circumvention of International Sanctions on Iran

The Treasury Department is also acting today to prevent the circumvention of international sanctions on Iran – including sanctions on oil trade with Iran – by publicly exposing numerous Iranian front companies, ships and banks that are part of the Government of Iran. The specific entities identified in today’s action are described in the accompanying Fact Sheet.

Treasury is identifying these Government of Iran entities pursuant to E.O. 13599, which blocks all property and interests in property within U.S. jurisdiction of the Government of Iran and of all Iranian financial institutions, and prohibits U.S. persons or those within U.S. jurisdiction from having dealings with them. To assist U.S. persons in complying with their obligation to freeze the assets of, and not to deal with, any such entities, the Treasury Department from time to time identifies entities that are owned or controlled by, or acting for or on behalf of, the Government of Iran.

Today’s identifications include four front companies for the Naftiran Intertrade Company (NICO) or the National Iranian Oil Company (NIOC) — Petro Suisse Intertrade Company SA; Hong Kong Intertrade Company; Noor Energy (Malaysia) Ltd.; and Petro Energy Intertrade Company. NICO intended to use Petro Energy Intertrade to evade western sanctions. The Treasury Department identified NICO and NIOC, both of which are centrally involved in the sale of Iranian oil, in 2008 as entities that are owned or controlled by the Government of Iran.

The Treasury Department is also identifying today the National Iranian Tanker Company (NITC) as a Government of Iran entity and, for the first time, the NITC fleet and various front companies belonging to NITC. In addition, the Treasury Department is also identifying 20 Iranian financial institutions for inclusion on its List of Specially Designated Nationals and Blocked Persons (SDN List).

These identifications highlight Iran’s attempts to evade sanctions through the use of front companies, as well as its attempts to conceal its tanker fleet by repainting, reflagging, or disabling GPS devices. They will assist U.S. persons in complying with E.O. 13599, and will also assist persons and entities around the world in complying with U.S. and international sanctions, including the European Union’s prohibition on the import of Iranian oil that went into effect on July 1, 2012.

U.S. persons are generally prohibited from engaging in any transactions with individuals or entities blocked pursuant to E.O 13382 or E.O. 13599, and any assets such persons may have under U.S. jurisdiction are blocked. Entry into the United States of aliens designated pursuant to E.O. 13382 is suspended under Presidential Proclamation 8693, Suspension of Entry of Aliens Subject to U.S. Security Council Travel Ban and International Emergency Economic Powers Act Sanctions.

For more information on today’s designations, please see the attached fact sheet.

​071212 Fact Sheet Iran Designations.pdf

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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 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.

————————————————————–

International criminal defense questions, but want to be anonymous?

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Foreign Terrorist Organizations [FTO] and Specially Designated Global Terrorists [SDGT] Entries Added to OFAC’s SDN List on May 24, 2012

May 24, 2012

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

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

ABDALLAH AZZAM BRIGADES (a.k.a. ABDULLAH AZZAM BRIGADES; a.k.a. YUSUF AL-‘UYAYRI BATTALIONS OF THE ABDULLAH AZZAM BRIGADES; a.k.a. ZIYAD AL-JARRAH BATTALIONS OF THE ABDULLAH AZZAM BRIGADES), Lebanon [FTO] [SDGT]

ABDULLAH AZZAM BRIGADES (a.k.a. ABDALLAH AZZAM BRIGADES; a.k.a. YUSUF AL-‘UYAYRI BATTALIONS OF THE ABDULLAH AZZAM BRIGADES; a.k.a. ZIYAD AL-JARRAH BATTALIONS OF THE ABDULLAH AZZAM BRIGADES), Lebanon [FTO] [SDGT]

YUSUF AL-‘UYAYRI BATTALIONS OF THE ABDULLAH AZZAM BRIGADES (a.k.a. ABDALLAH AZZAM BRIGADES; a.k.a. ABDULLAH AZZAM BRIGADES; a.k.a. ZIYAD AL-JARRAH BATTALIONS OF THE ABDULLAH AZZAM BRIGADES), Lebanon [FTO] [SDGT]

ZIYAD AL-JARRAH BATTALIONS OF THE ABDULLAH AZZAM BRIGADES (a.k.a. ABDALLAH AZZAM BRIGADES; a.k.a. ABDULLAH AZZAM BRIGADES; a.k.a. YUSUF AL-‘UYAYRI BATTALIONS OF THE ABDULLAH AZZAM BRIGADES), Lebanon [FTO] [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 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: mcnabb.mcnabbassociates

           Office Locations

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The Cybersecurity Market And Dangers Of U.S. Export Law

May 1, 2012

Forbes on April 30, 2012 released the following:

By Eric Savitz, Forbes Staff

Guest post written By Andrew Bigart

“This article examines the export controls applicable to the field of cybersecurity, an increasingly global industry in which U.S. companies sell their products and services to multinational companies, U.S. agencies with overseas operations, and even foreign governments, when permitted. The cybersecurity market – both public and private – hit $60 billion in 2011 and is expected to increase steadily over the next several years. Indeed, cybersecurity is one of the few defense “growth” areas to buck recent U.S. budget cuts.

As U.S. companies continue to expand in the market, however, so too does the risk of non-compliance with the confusing web of U.S. laws and regulations that govern export-related activities. U.S. law places the burden of complying with export controls and economic sanctions squarely on U.S. companies and their officers and employees. The cybersecurity industry is no exception, and may be particularly vulnerable to government scrutiny given the strategic need to protect U.S. technological advantages, critical infrastructure, and access to confidential information. In this regard, violating U.S. export laws can result in criminal law enforcement actions, jail time, and significant fines and penalties, including debarment from federal contracting.

U.S. Export Controls

The U.S. government maintains a complex set of regulations that govern the export of goods – including technology, software, and technical data – to foreign countries and specified foreign entities and individuals.

The State Department’s Directorate of Defense Trade Controls (DDTC) regulates the export of defense articles, related technical data, and defense services listed on the United States Munitions List (USML) through the International Traffic in Arms Regulations (ITAR). All manufacturers, exporters, and brokers of defense articles, related technical data and defense services are required to register with DDTC. Registration with DDTC is a prerequisite to applying for export licenses.

The Department of Commerce’s Bureau of Industry and Security (BIS) regulates anything that is not listed on the USML, including the export of commercial and dual-use commodities, software, and technology through the Export Administration Regulations (EAR). Both DDTC and BIS regulate exports depending on an item’s technical characteristics, destination, end-user, and end-use. In this regard, cybersecurity products and services present a challenge because the exports may contain a mixture of different software, encryption functions, and controlled technical information.

Finally, although not the focus of this article, it’s import to note that the Department of Treasury’s Office of Foreign Assets Control (OFAC) enforces trade embargoes and economic sanctions against specific countries (Cuba, Iran, North Korea – you get the picture) and individuals and entities (terrorists, narcotics traffickers and other bad guys). OFAC publishes the names of these ne’er-do-wells in the “Specially Designated Nationals” or “SDN” list. (BIS also maintains several lists of prohibited persons). Together, the Commerce and State export controls and OFAC sanctions programs are designed to protect U.S. foreign policy interests and to prevent U.S. persons from doing business with the wrong types of customers.

Classifying Cybersecurity Products and Services for Export Purposes

Whether an export license or other authorization is required for the export of a cybersecurity product is a fact-specific determination that includes a review of the items or services being exported, the destination, end-user and end-use. Given the complexity in classifying cybersecurity-related items, many companies request commodity jurisdiction determinations from the export agencies for guidance on whether their products are properly classified under the DDTC or BIS frameworks. These determinations, which are published, in part, by DDTC and BIS, highlight the breadth of USML and EAR classifications that potentially cover cybersecurity products and software. For example, DDTC has advised that a company’s “Customizable USB thumb drive that conducts targeted searches of digital assets for critical files” is classified under the USML section XI, which covers military electronics, as are certain military-grade GPS and cryptography products.

On the other hand, data manipulation software that uses Security Socket Layer (SSL) encryption usually qualifies for BIS’s “Mass Market Encryption” exception for items classified under Export Control Classification Numbers 5A992 and 5D992. This exception allows certain “publicly available” software to be exported to most countries without a license if the exporter registers with BIS by obtaining an Encryption Registration Number.

Moreover, both DDTC and BIS regulations define an export as including the disclosure (orally or visually) of technical information or software to a foreign person. Thus, a “deemed export” takes place when technology or software is released to foreign a person or national for visual inspection (such as reading technical specifications, plans, blueprints, etc.); when technology is exchanged orally with a foreign person or national; or when technology is made available by practice or application to a foreign person or nationals under the guidance of persons with knowledge of the technology. Depending on the nature of the technology and the country to which the technology is disclosed, releasing technology to a foreign person or national may require an export license (or in the case of ITAR possibly a Technical Assistance Agreement, depending on the individual circumstances).

Why Should The Cybersecurity Industry Care?

As the importance of cybersecurity has grown from a national defense perspective, so too has the U.S. government’s focus on regulating the export of sensitive technology. A number of recent U.S. government enforcement actions involve U.S. persons selling software, encryption products, and other cybersecurity related information abroad:

  • In 2010, a resident of China was sentenced by a federal court to serve 96 months in prison for his efforts to obtain sensitive encryption, communications, and global positioning system equipment without a DDTC license.
  • In 2009, a U.S. national working for Technical Integration Group was sentenced to six years in prison and paid $1.1 million for exporting mobile telecommunications equipment containing encryption properties to Iraq, in violation of the then U.S. embargo on Iraq.
  • In 2008, two companies paid administrative penalties to settle BIS allegations that the companies exported U.S.-origin engineering software to Iran and to companies on the BIS Entity List without the required licenses.
  • In 2002, Neopoint Inc. paid a $95,000 civil penalty to settle charges that it unlawfully exported 128-bit encryption software to South Korea.

The consequences for non-compliance with U.S. laws overseas are severe and can include large monetary fines per violation for businesses, and similar monetary fines and imprisonment for individuals. On top of that, in cases of significant violations, the consequences can include a denial of future export privileges and federal contract debarment, which is particular onerous for cybersecurity companies dependent primarily on business from U.S. government contracts.

What Can My Company Do To Minimize Risk When Selling Abroad?

The first step in minimizing export-related risk is to understand the nature of your business and potential customers, including the who, what, and where of every export transaction. The U.S. government expects companies that export to inform themselves of the facts of any export transaction and exercise reasonable care in complying with applicable U.S. export requirements. This process requires companies to determine the appropriate export classifications for their products and services. If any of your products or services falls under the USML, then you must register with DDTC as a manufacturer, exporter, or brokerer.

The next step is to develop a compliance plan that is tailored to your company’s specific export needs. A compliance plan should address, at a minimum, the following:

  • Overview of applicable laws;
  • A list of prohibited activities and employee responsibilities;
  • Regular compliance training for employees;
  • Required checking of all business partners and customers against OFAC’s SDN list on a transactional basis;
  • Rigorous internal financial and audit controls to monitor export and FCPA compliance; and
  • Required due diligence on all agents or independent contractors and required written contracts with export, economic sanctions, and FCPA prohibitions and certifications.

Finally, under U.S. law, exporters that become aware of – or should be aware of – “red flags” are required to resolve them before proceeding with a transaction. Monitoring the activities of your business partners overseas is particularly important because the conscious avoidance of knowledge of wrong doing is not a defense. Typical red flags include:

  • Transactions with incomplete information regarding end users, country of origin or destination;
  • Exportation of products that do not not fit the buyer’s line of business;
  • Unusual contract terms, payments in cash, or requests for high commissions;
  • Direct or indirect payments to government officials or their families or payments to persons outside the normal scope of a transaction;
  • Payment for travel, lodging, or business expenses or extravagant gifts or entertaining of government officials or their families; and
  • Consultants who are connected with a foreign government or political party.

What if a Potential Violation Arises?

Unfortunately, for some companies the legal risks of doing business abroad are not apparent until something goes wrong. If you discover questionable business practices regarding your export-related activities, stop the conduct in question immediately and report the activities to your company’s compliance officer. If your company finds itself in such a position, consider the option of a voluntary disclosure. Each of the agencies discussed above – Commerce, State, and OFAC – maintain procedures that encourage companies to self-report violations under certain circumstances. Although these programs do not allow companies to evade liability completely, they do offer reduced penalties and other incentives.

Conclusion

There is no doubt that the export market for cybersecurity products and services remains an attractive and growing market for U.S. exporters. Before taking the leap overseas, however, take the time to review and understand your company’s responsibilities under U.S. export control and economic sanctions. An ounce of prevention in this regard goes a long way in keeping your business profitable and out of trouble.”

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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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Enforcing existing sanctions on Iran

November 6, 2011

The Washington Times on November 4, 2011 released the following:

By Avi Jorisch -The Washington Times

“U.S. empowered to crack down on business with regime’s central bank

In recent years, the United States has imposed a punishing sanctions regime on Iran’s banking sector. To further increase Tehran’s level of financial pain, a great number of congressional and advocacy groups have repeatedly called on the White House to blacklist the Central Bank of Iran (CBI). Doing so, the thinking goes, would seriously hamper the Islamic republic’s ability to abuse international markets in its pursuit of nuclear weapons. Yet unbeknownst to most lawmakers and Washington policymakers, the U.S. Treasury actually hasblacklisted the CBI, and not once, but twice in recent years. The real question is why the U.S. government has not enforced its own sanctions regime.

The CBI has been accused of helping fund Iran’s nuclear weapons program, facilitate money transfers to terrorist organizations and proliferate weapons of mass destruction. The Treasury Department has publicly declared that between 2001 and 2006, the CBI facilitated a $50 million payment for Hezbollah. Treasury also has disclosed that the bank engaged in “deceptive practices,” including helping Iran’s Sepah and Melli banks, two financial institutions blacklisted by the United Nations, the European Union and United States for their role in facilitating illicit international transactions.

The United States maintains a number of “blacklists” sponsored by different agencies, including but not limited to the Departments of State, Treasury and Commerce. The Specially Designated Nationals (SDN) list is a broad compilation of persons and entities – a “list of lists” – administered by Treasury’s Office of Foreign Assets Control (OFAC). Those on the SDN list include not only persons and entities involved in terrorism, but also weapons proliferators, drug traffickers and those designated under country-specific sanctions programs.

Today, the SDN list has more than 6,000 entries, includingthe Central Bank of Iran. Unless specifically exempted, all U.S. persons and entities must block any property in which an SDN has an interest and report the action to OFAC. Blocked property may not be “transferred, withdrawn, exported, paid, or otherwise dealt in” without prior authorization from OFAC. If OFAC thinks a person or institution has violated the law, it has several options at its disposal, including cease-and-desist orders, civil penalties, suspension or revocation of licenses, and criminal charges.

The Treasury Department’s Web page clearly shows that the Central Bank of Iran appears on the SDN list of June 16, 2010, under the Iran country sanctions program. Treasury’s Financial Crimes Enforcement Network also took action against the CBI; in March 2008, it issued a banking advisory that fingered the bank for the “money laundering threat involving illicit Iranian activity.”

Treasury Secretary Timothy F. Geithner recently wrote to Congressthat “all options to increase the financial pressure on Iran are on the table, including the possibility of imposing additional sanctions against the CBI.” But the United States does not need new sanctions; it just needs to implement the existing regime, which could be a very potent tool for pursuing Iranian financial activity around the globe.

At this point, concerned parties should advocate a number of measures. The United States should ask banks that provide services of any kind to the Central Bank of Iran to cease doing so immediately. If they refuse to comply, the U.S. government should take immediate legal action in accordance with the PATRIOT Act and the U.S. Code, Title 18, Section 981, freezing any U.S.-based assets they hold and blocking their access to American markets.

Moving against the Central Bank would necessitate indirect action because the bank does not appear to possess assets in America. However, the U.S. government does have the power to freeze the funds deposited in a foreign bank on behalf of the Central Bank if the foreign bank maintains an account (known as an “interbank” or “correspondent account”) at a U.S. financial institution or has actual operations or property in the United States.

Washington should begin implementing the SDN as soon as possible. At a minimum, Treasury should designate one or a number of the biggest offenders among those engaging in business transactions with Iran’s Central Bank. This would likely cause many, if not most, of the companies and banks currently doing business with, or on behalf of, the Central Bank to cut their ties.

Policymakers in Washington are now keenly interested in imposing greater financial costs on the Iranian regime in an effort to derail its nuclear program. To do so, the need to target Iran’s Central Bank should be readily apparent. So, too, should the fact that levying real pressure on Iran’s most important economic construct is simply a matter of enacting already-existing restrictions and penalties. The Obama administration should do so without delay.”

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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 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.


[SDNTK] Entries Added on OFAC’s SDN List on September 21, 2011

September 28, 2011

On September 21, 2011, OFAC has added [SDNTK] Entries on the Specially Designated Nationals List (SDN List):

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

AS INVERSIONES S.A., Carrera 14A No. 151A-06 T4 104, Bogota, Colombia; NIT # 800224826-0 (Colombia) [SDNTK]

BARCENAS RIVERA, Mauricio, Calle 25 No. 35-21, Cali, Colombia; Calle 74 No. 10-33 Apto. 801, Bogota, Colombia; c/o BIO FORESTAL S.A.S., Medellin, Colombia; c/o C.I. DISERCOM S.A.S., Bogota, Colombia; c/o C.I. OKCOFFEE COLOMBIA S.A.S., Bogota, Colombia; c/o C.I. OKCOFFEE INTERNATIONAL S.A.S., Bogota, Colombia; c/o CUBICAFE S.A.S., Bogota, Colombia; c/o GANADERIA LA SORGUITA S.A.S., Medellin, Colombia; c/o PARQUES TEMATICOS S.A.S., Medellin, Colombia; c/o PROMO RAIZ S.A.S., Medellin, Colombia; c/o UNION DE CONSTRUCTORES CONUSA S.A.S., Bogota, Colombia; c/o C.I. METALURGIA EXTRACTIVA DE COLOMBIA S.A.S., Bogota, Colombia; c/o DESARROLLO MINERO RESPONSABLE C.I. S.A.S., Bogota, Colombia; c/o FUNDACION SALVA LA SELVA, Bogota, Colombia; c/o INVERPUNTO DEL VALLE S.A., Cali, Colombia; c/o LINEA AEREA PUEBLOS AMAZONICOS S.A.S., Bogota, Colombia; DOB
30 Jun 1977; POB Cali, Colombia; Cedula No. 94508327 (Colombia) (individual) [SDNTK]

C.I. PLANETA COMERCIAL S.A., Carrera 11 No. 67-63 Piso 2, Bogota, Colombia; NIT # 830079228-3 (Colombia) [SDNTK]

CASTRO, Jesus Maria, c/o NEGOCIOS INTERNACIONALES DEL ECUADOR NIDEGROUP S.A., Quito, Pichincha, Ecuador; c/o SNACK PARTY, Quito, Pichincha, Ecuador; DOB 20 Nov 1967; alt. DOB 28 Nov 1967; alt. DOB 11 Nov 1967; POB Dolores, Uruguay; Cedula No. 172101469-2 (Ecuador); Passport B716164 (Uruguay); alt. Passport C144880 (Uruguay); alt. Passport 02952296-8 (Uruguay) (individual) [SDNTK]

CBM DE COLOMBIA S.A., Carrera 35A No. 62-32, Bogota, Colombia; NIT # 830072893-1 (Colombia) [SDNTK]

COMERCIALIZADORA EMPRESARIAL TEAM BUSINESS S.A., Av. de los Shyris N35-174 y Suecia, Ofic. 508, Quito, Pichincha, Ecuador; RUC # 1792167248001 (Ecuador) [SDNTK]

GENETICA DEL SUR S.A., Padron 15001 S. Judicial 9 y 10 Seccion Catastral – Paraje Retamosa, Lavalleja, Uruguay; Cerrito 532 Of. 501, Montevideo, Uruguay; RUT # 215.950.390.012 (Uruguay) [SDNTK]

GRUPO MUNDO MARINO, S.A., Panama; Business Registration Document # 383112 (Panama) [SDNTK]

INTERNATIONAL GROUP OIRALIH, S.A. DE C.V., Boulevard Interlomas 5 Local W-13, Colonia San Fernando La Herradura, Huixquilucan, Estado de Mexico C.P. 52787, Mexico; R.F.C. IGO0106296K5 (Mexico) [SDNTK]

MEJIA ZULUAGA, Omar, Carrera 7 No. 62-43 Ap. 802, Bogota, Colombia; Carrera 14A No. 151A-06 Ap. 4-104, Bogota, Colombia; Carrera 19A No. 102-70, Bogota, Colombia; c/o AS INVERSIONES S.A., Bogota, Colombia; c/o CBM DE COLOMBIA S.A., Bogota, Colombia; c/o PRODUCTOS KIBONY S.A.S., Bogota,
Colombia; c/o T & T ANDINA S.A., Bogota, Colombia; c/o C.I. PLANETA COMERCIAL S.A., Bogota, Colombia; c/o FEDERAL CAPITAL GROUP, S.A., Panama City, Panama; DOB 18 Jan 1956; POB Villahermosa, Tolima, Colombia; Cedula No. 19316392 (Colombia) (individual) [SDNTK]

NEGOCIOS INTERNACIONALES DEL ECUADOR NIDEGROUP S.A., Calle B, Lote 27 y Calle A, Quito, Pichincha, Ecuador; RUC # 1792138884001 (Ecuador) [SDNTK]

PRODUCTOS KIBONY S.A.S., Carrera 35A No. 62-32, Bogota, Colombia; NIT # 830052461-6 (Colombia) [SDNTK]

R D I S.A., Calle 64A No. 32-52, Bogota, Colombia; NIT # 830054366-3 (Colombia) [SDNTK]

SNACK PARTY, Los Vinedos 19 y Venezuela, Quito, Pichincha, Ecuador; RUC # 1721014692001 (Ecuador) [SDNTK]

T & T ANDINA S.A., Carrera 69D No. 31-10, Bogota, Colombia; NIT # 830089233-3 (Colombia) [SDNTK]

URIBE CIFUENTES, Ana Maria, Calle 7 Sur No. 23-91 Apto. 804, Medellin, Colombia; c/o CIFUENTES URIBE Y CIA. S.C.S., Medellin, Colombia; c/o ECOVIVERO EL MATORRAL E.U., Medellin, Colombia; DOB 1 Feb 1980; POB Medellin, Colombia; Cedula No. 43162647 (Colombia) (individual) [SDNTK]

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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.

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