Treasury Designates Alleged Members And Supporters of Transnational Criminal Organizations

July 24, 2013

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

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

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

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

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

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

The Camorra

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

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

The Brothers’ Circle

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

Identifying Information:

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

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

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

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

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

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

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

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Douglas McNabb – McNabb Associates, P.C.’s
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————————————————————–

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

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

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

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OFAC SDN List Update: “Counter Terrorism Designations; Transnational Criminal Organizations Designations”

July 24, 2013

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

“OFFICE OF FOREIGN ASSETS CONTROL

Specially Designated Nationals List Update

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

ABETE, Mariano; DOB 03 Apr 1991; POB Naples, Italy (individual) [TCO].

DI LAURO, Marco; DOB 16 Jun 1980; POB Naples, Italy (individual) [TCO].

GUARINO, Rosario; DOB 26 Jun 1983; POB Naples, Italy (individual) [TCO].

MENNETTA, Antonio; DOB 03 Jan 1985; POB Naples, Italy (individual) [TCO].

RICCIO, Mario (a.k.a. RICCIO, Mariano); DOB 28 Jun 1991; POB Mugnano di Napoli, Italy (individual) [TCO].

YAYLA, Bulut (a.k.a. INCE, Samet); DOB 1981; POB Zonguldak, Turkey (individual) [SDGT].

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

AVUAR OOO (a.k.a. AVUAR LLC), 12/120, Komn 51, Ulitsa Demokraticheskaya, Samara 443031, Russia; National ID No. 1036300456213 (Russia); alt. National ID No. 14565711 (Russia); alt. National ID No. 6315565439 (Russia) [TCO].

GUGA ARM SRO (a.k.a. GUGA ARM LTD), Dr. Davida Bechera 907/27, Karlovy Vary 36001, Czech Republic; National ID No. 27994783 (Czech Republic) [TCO].”

————————————————————–

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

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

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

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

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

————————————————————–

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC): “Treasury Sanctions Significant Members Of MS-13”

June 5, 2013

The U.S. Department of the Treasury on June 5, 2013 released the following:

“Designation Targets Notorious Gang Mara Salvatrucha (MS-13)

WASHINGTON – The U.S. Department of the Treasury today designated six members of the notorious El Salvadoran gang Mara Salvatrucha (MS-13) pursuant to Executive Order (E.O.) 13581, which targets transnational criminal organizations (TCOs) and their supporters. Today’s actions, supported extensively by the U.S. Immigration and Customs Enforcement’s (ICE) Homeland Security Investigations (HSI), are part of the Treasury Department’s ongoing efforts to target the leadership of global criminal organizations, including MS-13, that threaten innocent people and legitimate business around the world, including in the United States. In October 2012, MS-13 became the first transnational criminal street gang to be designated by Treasury as a TCO. MS-13 has been involved in serious criminal activity, in the United States and around the world, including human smuggling, sex trafficking, drug trafficking, kidnapping, murder, assassinations, racketeering, blackmail, extortion, and immigration offenses.

“MS-13 is an extremely violent and dangerous gang responsible for a multitude of crimes that directly threaten the welfare and security of U.S. citizens, as well as peoples throughout Central America,” said Adam Szubin, Director of Treasury’s Office of Foreign Assets Control. “We will continue to target the leadership and financial networks supporting MS-13, and work with our law enforcement partners from across the United States and around the world to disrupt their criminal activities.”

“Today’s designation of six MS-13 leaders is the result of Homeland Security Investigation’s National Gang Unit and OFAC’s joint partnership to further strike at the financial heart of one of the most dangerous transnational criminal gangs in the world today,” said ICE Director John Morton. “This powerful tool will provide HSI and its local, state, federal and international law enforcement partners to further disrupt MS-13 financial networks and violent operations. “History has proven that we can successfully take down organized crime groups when we combine sophisticated investigative techniques with tough street level enforcement, cutting off cash flows, contraband and collaborators to ensure they no longer find safe haven in our communities.”

Today’s designations of six individuals working for or on behalf of MS-13 are designed to further disrupt the activities of MS-13 and to protect the U.S. and international financial system from abuse. As active members and leaders, these individuals are heavily involved in directing and participating in illicit activity, such as drug trafficking, money laundering, extortion, and murder. Borromeo Enrique Henriquez Solorzano, incarcerated in El Salvador, is widely regarded as the Central American leader of the group and frequently acts as the spokesperson for the MS-13 gang in El Salvador. Several other MS-13 leaders, including Marvin Geovanny Monterrosa Larios, Moises Humberto Rivera Luna, and Saul Antonio Turcios Angel, have been indicted in the United States for racketeering, murder, and other violent crimes. Moris Alexander Bercian Manchon has been involved in narcotics trafficking operations on behalf of the organization and Jose Misael Cisneros Rodriguez is both an MS-13 crime boss and a narcotics trafficker.

MS-13 consists of more than 30,000 members and operates in at least five countries, including the United States. It is one of the most dangerous criminal gangs in the world today. MS-13 promotes its illicit interests through murder, kidnapping, blackmail, extortion, and assassination, including carrying out numerous murders within the United States.

U.S. persons and businesses are generally prohibited from engaging in any transactions with the individuals designated today, and any assets of those designees subject to U.S. jurisdiction are frozen.

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

Identifiers

Name: Moris Alexander Bercian Manchon
AKA: “El Barney”
Date of Birth: October 30, 1984
Place of Birth: San Salvador, El Salvador
Nationality: Salvadoran

Name: Jose Misael Cisneros Rodriguez,
AKA: Jose Misal Cisneros
AKA: “Medio Millon”
AKA: “Half Million”
Date of Birth: October 2, 1976
Place of Birth: Agua Caliente, Chalatenango, El Salvador
Nationality: Salvadoran

Name: Marvin Geovanny Monterrosa-Larios
AKA: Marvin Jeovanny Monterrosa-Larios
AKA: “Enano”
Date of Birth: May 21, 1974
Place of Birth: San Miguel, San Miguel, El Salvador
Nationality: Salvadoran

Name: Moises Humberto Rivera-Luna,
AKA: “Santos”
AKA: “Viejo Santos”
Date of Birth: May 23, 1969
Place of Birth: San Salvador, El Salvador
Nationality: Salvadoran

Name: Saul Antonio Turcios Angel
AKA: “El Trece”
AKA: “Shayboys”
Date of Birth: May 17, 1978
Place of Birth: Zaragoza, La Libertad, El Salvador
Nationality: Salvadoran

Name: Borromeo Enrique Henriquez Solorzano
AKA: Racson Mario Rivera Arias
AKA: “El Diablo Pequeno”
AKA: “El Diablo”
AKA: “El Diablito”
AKA: “El Diablito De Hollywood”
Date of Birth: July 27, 1978
Place of Birth: San Salvador, El Salvador
Nationality: Salvadoran”

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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): “Transnational Criminal Organizations Designations”

June 5, 2013

The U.S. Department of the Treasury on June 5, 2013 released the following:

“OFFICE OF FOREIGN ASSETS CONTROL

Specially Designated Nationals List Update:

Please visit this chart for more information on these designations.

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

BERCIAN MANCHON, Moris Alexander (a.k.a. “EL BARNEY”); DOB 30 Oct 1984; POB San Salvador, El Salvador; nationality El Salvador (individual) [TCO].

CISNEROS RODRIGUEZ, Jose Misael (a.k.a. CISNEROS, Jose Misal; a.k.a. “HALF MILLION”; a.k.a. “MEDIO MLON”); DOB 02 Oct 1976; POB Agua Caliente, Chalatenango, El Salvador; nationality El Salvador (individual) [TCO].

HENRIQUEZ SOLORZANO, Borromeo Enrique (a.k.a. RIVERA ARIAS, Racson Mario; a.k.a. “EL DIABLITO”; a.k.a. “EL DIABLITO DE HOLLYWOOD”; a.k.a. “EL DIABLO”; a.k.a. “EL DIABLO PEQUENO”); DOB 27 Jul 1978; POB San Salvador, El Salvador; nationality El Salvador (individual) [TCO].

MONTERROSA-LARIOS, Marvin Geovanny (a.k.a. MONTERROSA-LARIOS, Marvin Jeovanny; a.k.a. “ENANO”); DOB 21 May 1974; POB San Miguel, San Miguel, El Salvador; nationality El Salvador (individual) [TCO].

RIVERA-LUNA, Moises Humberto (a.k.a. “SANTOS”; a.k.a. “VIEJO SANTOS”); DOB 23 May 1969; POB San Salvador, El Salvador; nationality El Salvador (individual) [TCO].

TURCIOS ANGEL, Saul Antonio (a.k.a. “EL TRECE”; a.k.a. “SHAYBOYS”); DOB 17 May 1978; POB Zaragoza, La Libertad, El Salvador; nationality El Salvador (individual) [TCO].”

————————————————————–

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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Transnational Criminal Organizations [TCO] Entries Added to OFAC’s SDN List on August 1, 2012

August 6, 2012

On August 1, 2012, OFAC has added [TCO] Entries to the Specially Designated Nationals List (SDN List):

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

CATERINO, Mario; DOB 14 Jun 1957; POB Casal di Principe, Italy (individual) [TCO].

DELL’AQUILA, Giuseppe (a.k.a. “PEPPE ‘O CIUCCIO”); DOB 20 Mar 1962; POB Giugliano, Campania, Italy (individual) [TCO].

DI MAURO, Paolo; DOB 19 Oct 1952; POB Naples, Italy (individual) [TCO].

IOVINE, Antonio (a.k.a. “O’NINNO”); DOB 20 Sep 1964; POB San Cipriano d’Aversa, Italy (individual) [TCO].

ZAGARIA, Michele (a.k.a. “CAPASTORTA”; a.k.a. “CAPOSTORTA”; a.k.a. “ISS”; a.k.a. “MANERA”; a.k.a. “ZIO”); DOB 21 May 1958; POB San Cipriano d’Aversa, Italy (individual) [TCO].

“CAPASTORTA” (a.k.a. ZAGARIA, Michele; a.k.a. “CAPOSTORTA”; a.k.a. “ISS”; a.k.a. “MANERA”; a.k.a. “ZIO”); DOB 21 May 1958; POB San Cipriano d’Aversa, Italy (individual) [TCO].

“CAPOSTORTA” (a.k.a. ZAGARIA, Michele; a.k.a. “CAPASTORTA”; a.k.a. “ISS”; a.k.a. “MANERA”; a.k.a. “ZIO”); DOB 21 May 1958; POB San Cipriano d’Aversa, Italy (individual) [TCO].

“ISS” (a.k.a. ZAGARIA, Michele; a.k.a. “CAPASTORTA”; a.k.a. “CAPOSTORTA”; a.k.a. “MANERA”; a.k.a. “ZIO”); DOB 21 May 1958; POB San Cipriano d’Aversa, Italy (individual) [TCO].

“MANERA” (a.k.a. ZAGARIA, Michele; a.k.a. “CAPASTORTA”; a.k.a. “CAPOSTORTA”; a.k.a. “ISS”; a.k.a. “ZIO”); DOB 21 May 1958; POB San Cipriano d’Aversa, Italy (individual) [TCO].

“O’NINNO” (a.k.a. IOVINE, Antonio); DOB 20 Sep 1964; POB San Cipriano d’Aversa, Italy (individual) [TCO].

“PEPPE ‘O CIUCCIO” (a.k.a. DELL’AQUILA, Giuseppe); DOB 20 Mar 1962; POB Giugliano, Campania, Italy (individual) [TCO].

“ZIO” (a.k.a. ZAGARIA, Michele; a.k.a. “CAPASTORTA”; a.k.a. “CAPOSTORTA”; a.k.a. “ISS”; a.k.a. “MANERA”); DOB 21 May 1958; POB San Cipriano d’Aversa, Italy (individual) [TCO].

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Treasury Sanctions Members of the Camorra

8/1/2012

Action Targets Major Transnational Criminal Organization

WASHINGTON – The U.S. Department of the Treasury today designated five key leaders of the Camorra, one of Europe’s largest criminal organizations, under its authority to impose sanctions targeting transnational organized crime. The Camorra is involved in money laundering, extortion, alien smuggling, robbery, blackmail, kidnapping, political corruption, and counterfeiting around the world. It is one of four transnational criminal organizations (TCOs) specifically identified by the President for sanctions under E.O. 13581 (Blocking Property of Transnational Criminal Organizations), along with the Brothers’ Circle, the Yakuza, and the Zetas. The Camorra leaders designated today are Antonio Iovine, Michele Zagaria, Mario Caterino, Paolo Di Mauro, and Giuseppe Dell’Aquila, all leaders or senior members of Camorra clans. Each of these five individuals is designated for acting for or on behalf of, or providing support to, the Camorra.

President Obama identified the Camorra as a significant TCO in the Annex to E.O. 13581 on July 24, 2011, and charged the Treasury Department with pursuing additional sanctions against its members and supporters. Drawing on this authority, the Treasury Department is taking action against the Camorra by identifying and designating these five key leaders. Today’s action freezes any assets they may have within the jurisdiction of the United States and prohibits any transactions with them by U.S. persons. These efforts protect the U.S. financial system from transnational criminal organizations and expose and disrupt the actions of individuals who are supporting or acting for or on behalf of the Camorra.

“This action is designed to squeeze the Camorra out of the global financial system and protect the U.S. financial system from laundering of its criminal proceeds. We will continue to pursue members and supporters of the Camorra, and today’s action against the group’s leadership will help us cast an even larger net to expose their financial facilitators and associates wherever they may operate,” said Under Secretary for Terrorism and Financial Intelligence David S. Cohen.

The Camorra operates internationally and is involved in serious criminal activity, such as counterfeiting and narcotics trafficking. In March 2012 more than a billion dollars worth of Camorra assets reportedly were seized by Italian law enforcement.

Mario Caterino is a Camorra clan leader, identified at the time of his arrest in May 2011 as the second in command of the Casalesi clan. He is serving a life sentence in Italy for conspiracy and murder.

Giuseppe Dell’Aquila is described as the head of the Mallardo clan. He is believed to have played a key role in investing in and managing Camorra holding companies. Arrested in Italy in May 2011, he is serving a sentence for conspiracy, money laundering, robbery, and the receipt of stolen goods.

Paolo di Mauro was the third most wanted fugitive in Italy at the time of his arrest in Spain in January 2010. He is a leader of the Contini clan and is currently serving a 17-year sentence for conspiracy and murder.

Antonio Iovine is a leader of the Camorra’s Casalesi clan. He was arrested in November 2010 and is serving a life sentence for conspiracy and murder.

Michele Zagaria is a leader of the Casalesi clan and was captured by Italian authorities in December 2011 after 15 years as a fugitive. He is serving a life sentence for conspiracy, murder, extortion, and robbery.

Identifying Information:

CATERINO, Mario

DOB: 14 June 1957

POB: Casal di Principe, Italy

DELL’AQUILA, Giuseppe

AKA: PEPPE ‘O CIUCCIO

DOB: 20 March 1962

POB: Giugliano Campania, Italy

DI MAURO, Paolo

DOB: 19 October 1952

POB: Naples, Italy

IOVINE, Antonio

AKA: O’NINNO

DOB: 20 September 1964

POB: San Cipriano d’Aversa, Italy

ZAGARIA, Michele

AKA: CAPASTORTA

AKA: CAPOSTORTA

AKA: ISS

AKA: MANERA

AKA: ZIO

DOB: 21 May 1958

POB: San Cipriano d’Aversa, Italy”

————————————————————–

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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Transnational Criminal Organizations [TCO] Entries Added to OFAC’s SDN List on June 6, 2012

June 6, 2012

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

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

KAKHA RUSTAVSKIY (a.k.a. KOSTOV, Nikolay Lyudmilo; a.k.a. ROSTOV, Nicholas; a.k.a. SEPIASHVILI, Moshe Israel; a.k.a. SHUSHANASHVILI, Kajaver; a.k.a. SHUSHANASHVILI, Kakha; a.k.a. SHUSHANASHVILI, Kakhaber Pavlovich), 8 Rukavishnikov Street, Mariinskiy Posad, Chuvash Republic, Russia; DOB 8 Feb 1972; POB Rustavi, Georgia; alt. POB Kutaisi, Georgia; nationality Georgia (individual) [TCO]

KOBA RUSTAVSKIY (a.k.a. SHEMAZASHVILI, Koba Shalvovich; a.k.a. SHERMAZASHVILI, Koba; a.k.a. “TSITSILA”); DOB 1974; POB Rustavi, Georgia (individual) [TCO]

KOSTOV, Nikolay Lyudmilo (a.k.a. ROSTOV, Nicholas; a.k.a. SEPIASHVILI, Moshe Israel; a.k.a. SHUSHANASHVILI, Kajaver; a.k.a. SHUSHANASHVILI, Kakha; a.k.a. SHUSHANASHVILI, Kakhaber Pavlovich; a.k.a. “KAKHA RUSTAVSKIY”), 8 Rukavishnikov Street, Mariinskiy Posad, Chuvash Republic, Russia; DOB 8 Feb 1972; POB Rustavi, Georgia; alt. POB Kutaisi, Georgia; nationality Georgia (individual) [TCO]

LASHA RUSTAVSKI (a.k.a. MALGASOV, Ymar; a.k.a. SHUSHANASHVILI, Iasha Pavlovich; a.k.a. SHUSHANASHVILI, Lasha Pavlovich; a.k.a. “LASHA RUSTAVSKY”; a.k.a. “LASHA TOLSTY”); DOB 25 Jul 1961; POB Rustavi, Georgia; nationality Georgia (individual) [TCO]

LASHA RUSTAVSKY (a.k.a. MALGASOV, Ymar; a.k.a. SHUSHANASHVILI, Iasha Pavlovich; a.k.a. SHUSHANASHVILI, Lasha Pavlovich; a.k.a. “LASHA RUSTAVSKI”; a.k.a. “LASHA TOLSTY”); DOB 25 Jul 1961; POB Rustavi, Georgia; nationality Georgia (individual) [TCO]

LASHA TOLSTY (a.k.a. MALGASOV, Ymar; a.k.a. SHUSHANASHVILI, Iasha Pavlovich; a.k.a. SHUSHANASHVILI, Lasha Pavlovich; a.k.a. “LASHA RUSTAVSKI”; a.k.a. “LASHA RUSTAVSKY”); DOB 25 Jul 1961; POB Rustavi, Georgia; nationality Georgia (individual) [TCO]

MALGASOV, Ymar (a.k.a. SHUSHANASHVILI, Iasha Pavlovich; a.k.a. SHUSHANASHVILI, Lasha Pavlovich; a.k.a. “LASHA RUSTAVSKI”; a.k.a. “LASHA RUSTAVSKY”; a.k.a. “LASHA TOLSTY”); DOB 25 Jul 1961; POB Rustavi, Georgia; nationality Georgia (individual) [TCO]

MIRZOEV, Temuri (a.k.a. MIRZOYEV, Temuri Suleimanovich; a.k.a. “TIMUR SVERDLOVSKIY”; a.k.a. “TIMUR TBILISI”; a.k.a. “TIMUR TBILISSKIY”); DOB 7 May 1957; POB Tbilisi, Georgia (individual) [TCO]

MIRZOYEV, Temuri Suleimanovich (a.k.a. MIRZOEV, Temuri; a.k.a. “TIMUR SVERDLOVSKIY”; a.k.a. “TIMUR TBILISI”; a.k.a. “TIMUR TBILISSKIY”); DOB 7 May 1957; POB Tbilisi, Georgia (individual) [TCO]

ROSTOV, Nicholas (a.k.a. KOSTOV, Nikolay Lyudmilo; a.k.a. SEPIASHVILI, Moshe Israel; a.k.a. SHUSHANASHVILI, Kajaver; a.k.a. SHUSHANASHVILI, Kakha; a.k.a. SHUSHANASHVILI, Kakhaber Pavlovich; a.k.a. “KAKHA RUSTAVSKIY”), 8 Rukavishnikov Street, Mariinskiy Posad, Chuvash Republic, Russia; DOB 8 Feb 1972; POB Rustavi, Georgia; alt. POB Kutaisi, Georgia; nationality Georgia (individual) [TCO]

SEPIASHVILI, Moshe Israel (a.k.a. KOSTOV, Nikolay Lyudmilo; a.k.a. ROSTOV, Nicholas; a.k.a. SHUSHANASHVILI, Kajaver; a.k.a. SHUSHANASHVILI, Kakha; a.k.a. SHUSHANASHVILI, Kakhaber Pavlovich; a.k.a. “KAKHA RUSTAVSKIY”), 8 Rukavishnikov Street, Mariinskiy Posad, Chuvash Republic, Russia; DOB 8 Feb 1972; POB Rustavi, Georgia; alt. POB Kutaisi, Georgia; nationality Georgia (individual) [TCO]

SHEMAZASHVILI, Koba Shalvovich (a.k.a. SHERMAZASHVILI, Koba; a.k.a. “KOBA RUSTAVSKIY”; a.k.a. “TSITSILA”); DOB 1974; POB Rustavi, Georgia (individual) [TCO]

SHERMAZASHVILI, Koba (a.k.a. SHEMAZASHVILI, Koba Shalvovich; a.k.a. “KOBA RUSTAVSKIY”; a.k.a. “TSITSILA”); DOB 1974; POB Rustavi, Georgia (individual) [TCO]

SHUSHANASHVILI, Iasha Pavlovich (a.k.a. MALGASOV, Ymar; a.k.a. SHUSHANASHVILI, Lasha Pavlovich; a.k.a. “LASHA RUSTAVSKI”; a.k.a. “LASHA RUSTAVSKY”; a.k.a. “LASHA TOLSTY”); DOB 25 Jul 1961; POB Rustavi, Georgia; nationality Georgia (individual) [TCO]

SHUSHANASHVILI, Kajaver (a.k.a. KOSTOV, Nikolay Lyudmilo; a.k.a. ROSTOV, Nicholas; a.k.a. SEPIASHVILI, Moshe Israel; a.k.a. SHUSHANASHVILI, Kakha; a.k.a. SHUSHANASHVILI, Kakhaber Pavlovich; a.k.a. “KAKHA RUSTAVSKIY”), 8 Rukavishnikov Street, Mariinskiy Posad, Chuvash Republic, Russia; DOB 8 Feb 1972; POB Rustavi, Georgia; alt. POB Kutaisi, Georgia; nationality Georgia (individual) [TCO]

SHUSHANASHVILI, Kakha (a.k.a. KOSTOV, Nikolay Lyudmilo; a.k.a. ROSTOV, Nicholas; a.k.a. SEPIASHVILI, Moshe Israel; a.k.a. SHUSHANASHVILI, Kajaver; a.k.a. SHUSHANASHVILI, Kakhaber Pavlovich; a.k.a. “KAKHA RUSTAVSKIY”), 8 Rukavishnikov Street, Mariinskiy Posad, Chuvash Republic, Russia; DOB 8 Feb 1972; POB Rustavi, Georgia; alt. POB Kutaisi, Georgia; nationality Georgia (individual) [TCO]

SHUSHANASHVILI, Kakhaber Pavlovich (a.k.a. KOSTOV, Nikolay Lyudmilo; a.k.a. ROSTOV, Nicholas; a.k.a. SEPIASHVILI, Moshe Israel; a.k.a. SHUSHANASHVILI, Kajaver; a.k.a. SHUSHANASHVILI, Kakha; a.k.a. “KAKHA RUSTAVSKIY”), 8 Rukavishnikov Street, Mariinskiy Posad, Chuvash Republic, Russia; DOB 8 Feb 1972; POB Rustavi, Georgia; alt. POB Kutaisi, Georgia; nationality Georgia (individual) [TCO]

SHUSHANASHVILI, Lasha Pavlovich (a.k.a. MALGASOV, Ymar; a.k.a. SHUSHANASHVILI, Iasha Pavlovich; a.k.a. “LASHA RUSTAVSKI”; a.k.a. “LASHA RUSTAVSKY”; a.k.a. “LASHA TOLSTY”); DOB 25 Jul 1961; POB Rustavi, Georgia; nationality Georgia (individual) [TCO]

TIMUR SVERDLOVSKIY (a.k.a. MIRZOEV, Temuri; a.k.a. MIRZOYEV, Temuri Suleimanovich; a.k.a. “TIMUR TBILISI”; a.k.a. “TIMUR TBILISSKIY”); DOB 7 May 1957; POB Tbilisi, Georgia (individual) [TCO]

TIMUR TBILISI (a.k.a. MIRZOEV, Temuri; a.k.a. MIRZOYEV, Temuri Suleimanovich; a.k.a. “TIMUR SVERDLOVSKIY”; a.k.a. “TIMUR TBILISSKIY”); DOB 7 May 1957; POB Tbilisi, Georgia (individual) [TCO]

TIMUR TBILISSKIY (a.k.a. MIRZOEV, Temuri; a.k.a. MIRZOYEV, Temuri Suleimanovich; a.k.a. “TIMUR SVERDLOVSKIY”; a.k.a. “TIMUR TBILISI”); DOB 7 May 1957; POB Tbilisi, Georgia (individual) [TCO]

TSITSILA (a.k.a. SHEMAZASHVILI, Koba Shalvovich; a.k.a. SHERMAZASHVILI, Koba; a.k.a. “KOBA RUSTAVSKIY”); DOB 1974; POB Rustavi, Georgia (individual) [TCO]

VAGIN, Vladimir Viktorovich (a.k.a. “VAGON”), Sadaf 2 Sector, Tower C06-T06, Apartment 603, Dubai 32900, United Arab Emirates; DOB 3 Feb 1966; POB Raditshevo, Russia; nationality Russia (individual) [TCO]

VAGON (a.k.a. VAGIN, Vladimir Viktorovich), Sadaf 2 Sector, Tower C06-T06, Apartment 603, Dubai 32900, United Arab Emirates; DOB 3 Feb 1966; POB Raditshevo, Russia; nationality Russia (individual) [TCO]

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

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————————————————————–

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

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

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

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Transnational Criminal Organizations [TCO] Entries Added to OFAC’s SDN List on February 23, 2012

February 23, 2012

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

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

ROKUDAIME YAMAGUCHI-GUMI (a.k.a. SIXTH YAMAGUCHI-GUMI; a.k.a. YAMAGUCHIGUMI), 4-3-1 Shinohara-honmachi, Nada-Ku, Kobe City, Hyogo, Japan [TCO]

SHINODA, Kenichi (a.k.a. TSUKASA, Shinobu); DOB 25 Jan 1942; POB Oita Kyushu, Japan (individual) [TCO]

SIXTH YAMAGUCHI-GUMI (a.k.a. ROKUDAIME YAMAGUCHI-GUMI; a.k.a. YAMAGUCHIGUMI), 4-3-1 Shinohara-honmachi, Nada-Ku, Kobe City, Hyogo, Japan [TCO]

TAKAYAMA, Kiyoshi; DOB 5 Sep 1947; POB Tsushimasi, Aichi Prefecture, Japan (individual) [TCO]

TSUKASA, Shinobu (a.k.a. SHINODA, Kenichi); DOB 25 Jan 1942; POB Oita Kyushu, Japan (individual) [TCO]

YAMAGUCHI-GUMI (a.k.a. ROKUDAIME YAMAGUCHI-GUMI; a.k.a. SIXTH YAMAGUCHI-GUMI), 4-3-1 Shinoharahonmachi, Nada-Ku, Kobe City, Hyogo, Japan [TCO]

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Treasury Imposes Sanctions On Key Members Of The Yakuza And Brothers’ Circle Criminal Organizations

2/23/2012
WASHINGTON – The U.S. Department of the Treasury today designated seven key members and associates of the Brothers’ Circle crime syndicate as well as the largest group within the Japanese Yakuza, the Yamaguchi-gumi, and two Yamaguchi-gumi leaders. These are the first designations by Treasury pursuant to Executive Order (E.O.) 13581, which President Obama issued in 2011 to target and disrupt significant transnational criminal organizations (TCOs).

President Obama identified the Brothers’ Circle and the Yakuza as significant TCOs in the Annex to E.O. 13581 (Blocking Property of Transnational Criminal Organizations) of July 24, 2011, and charged the Treasury Department with pursuing additional sanctions against their members and supporters. Drawing on this authority, the Treasury Department today is identifying key members and associates of these transnational organized criminal networks, freezing any assets the designated persons may have within the jurisdiction of the United States and prohibiting any transactions with them by U.S. persons.

“Today’s action casts a spotlight on key members of criminal organizations that have engaged in a wide range of serious crimes across the globe,” said David S. Cohen, Treasury Under Secretary for Terrorism and Financial Intelligence. “We will continue to work with our international partners to target those who deal in violence, narcotics, money laundering, and the exploitation of women and children. Today’s designations are just the first under our new our sanctions authority to target transnational criminal organizations and isolate them from the global financial system.”

THE BROTHERS’ CIRCLE

The Brothers’ Circle (f.k.a. Family of Eleven; f.k.a. The Twenty) is a multi-ethnic criminal group composed of leaders and senior members of several Eurasian criminal groups largely based in countries of the former Soviet Union but operating in Europe, the Middle East, Africa and Latin America. The Brothers’ Circle serves as a coordinating body for several criminal networks, mediating disputes between the individual criminal networks and directing member criminal activity globally.

The individuals designated today represent criminal syndicates that operate throughout Eurasia and the Gulf, specifically within Kyrgyzstan, Uzbekistan, Russia and the United Arab Emirates (UAE). They include key Brothers’ Circle members Vladislav Leontyev, Vasiliy Khristoforov, Kamchybek Kolbayev and Gafur Rakhimov. Lazar Shaybazyan, Aleksandr Manuylov and Aleksey Zaytsev are designated today based on their support to Vladislav Leontyev. Several of these individuals reside in Dubai, UAE.

Two key Brothers’ Circle members, Vladislav Leontyev and Vasiliy Khristoforov, are targeted today for acting for or on behalf of the Brothers’ Circle. Both have been involved in criminal activities, including narcotics trafficking, and were involved in a shooting between regional factions within Russian organized criminal networks over an attempt to seize control of a local precious metals enterprise. Leontyev is currently wanted by Russian authorities for illegal transactions involving precious metals and narcotics.

Kamchybek Kolbayev acts for or on behalf of the Brothers’ Circle by serving as the Brothers’ Circle “overseer” for its Central Asian activities, including narcotics trafficking. In June 2011, President Obama identified Kolbayev as a significant foreign narcotics trafficker under the Foreign Narcotics Kingpin Designation Act. Kolbayev is wanted in Kyrgyzstan for organized crimes and crimes involving the use of weapons/explosives, and organized/transnational crime.

As a key member of the Brothers’ Circle, Gafur Rakhimov acts for or on behalf of the Brothers’ Circle. Rakhimov is one of the leaders of Uzbek organized crime with a specialty in the organized production of drugs in the countries of Central Asia. He has operated major international drug syndicates involving the trafficking of heroin.

Aleksey Zaytsev, who acts for or on behalf of the Brothers’ Circle key member Vladislav Leontyev, is involved in fraud and a variety of other such activities as fraud, including his 2008 participation in a financial pyramid scheme involving the St. Petersburg-based Business Club Rubin.

Lazar Shaybazyan and Aleksandr Manuylov also act for or on behalf of, Brothers’ Circle key member Vladislav Leontyev.

The YAKUZA

The Yakuza (a.k.a. Boryokudan; a.k.a. Gokudo) was listed in the Annex to E.O. 13581 for its involvement in serious criminal activities, including weapons trafficking, prostitution, human trafficking, drug trafficking, fraud and money laundering. The Yamaguchi-gumi is the largest and most prominent of the Yakuza’s crime families, and is being designated today for acting for or on behalf of the Yakuza. The Yamaguchi-gumi has a pyramid structure with a kumicho (“godfather”) at the top. Today’s action also imposes sanctions on Kenichi Shinoda, the Yamaguchi-gumi kumicho since August 2005, as well as the Yamaguchi-gumi’s wakagashira (“deputy godfather”), Kiyoshi Takayama, both for acting for or on behalf of Yamaguchi-gumi.

As leaders of the Yamaguchi-gumi crime syndicate, both Shinoda and Takayama play key roles in directing the syndicate’s policies and settling disputes with other Yakuza syndicates. The Yamaguchi-gumi is involved in criminal endeavors in Japan and abroad, including drug trafficking, human trafficking, extortion, prostitution, fraud and money laundering. The Yamaguchi-gumi is estimated to generate billions of dollars annually in illicit proceeds.

Today’s action is designed to protect the integrity of the U.S. financial system, to prevent U.S. financial institutions from being used unwittingly to facilitate the unlawful activities of these groups, and to deny the named individuals and entity access to the U.S. economy.

Identifiers

1. KHRISTOFOROV, Vasily Alexandrovich (a.k.a. KHRISTOFOROV, Vasiliy; a.k.a. “VASYA”; a.k.a. “VOSKRES”), Murjan 6 Sector, Tower D01-T03.1, Apartment 401, Dubai 39409, United Arab Emirates; DOB 12 Mar 1972; POB Gorky Oblast, Russia; National ID No. 76481815 (United Arab Emirates); Passport 63-7186356 (Russia) (individual) [TCO]

1. KOLBAYEV, Kamchybek Asanbekovich (a.k.a. KOLBAEV, Kamchibek; a.k.a. KOLBAYEV, Kamchy; a.k.a. KOLBAYEV, Kamchi; a.k.a. KOLBAYEV, Kamchibek; a.k.a. “KAMCHI BISHKEKSKIY”; a.k.a. “KOLYA-BISHKEKSKIY”; a.k.a. “KOLYA-KYRGYZ”), Bahar 1 Sector, C09-T02 Tower, Apartment 3203, Dubai 31672, United Arab Emirates; Volokolamskoye Shosse, House 15/22, Moscow, Russia; DOB 3 Aug 1974; alt. DOB 1 Jan 1973; POB Cholpon-Ata, Kyrgyzstan; citizen Kyrgyzstan; Passport A0832532 (Kyrgyzstan) expires 17 Mar 2009 (individual) [SDNTK] [TCO]

1. LEONTYEV, Vladislav Vladimirovich (a.k.a. LEONTIEV, Vladislav; a.k.a. LEONTIEV, Vlantislav; a.k.a. LEONTYEV, Vyacheslav; a.k.a. LEONTYEV, Vadim; a.k.a. LEONTYEV, Vadik; a.k.a. “BELOBRYSYY”; a.k.a. “BELYY”), Al-Fattan Building, Dubai, United Arab Emirates; DOB 5 Jul 1971; POB Gorky, Russia; alt. POB Caracas, Venezuela; National ID No. 60229551 (United Arab Emirates); Passport AB4065216 (Greece); alt. Passport H2214925 (Ghana); alt. Passport C1602418 (Venezuela) (individual) [TCO]

1. MANUYLOV, Aleksandr Leonidovich (a.k.a. MANUILOV, Alexander; a.k.a. MANUYLOV, Alexander; a.k.a. “SASHA SAMARSKIY”); DOB 3 Mar 1962; POB Russia; Passport 3056306 (Russia) (individual) [TCO]
2. RAKHIMOV, Gafur Akhmedovich (a.k.a. RAKHIMOV, Gofur-Arslonbek; a.k.a. RAKHIMOV, Gafur-Arslanbek Akhmedovich), The Meadows, Villa Number 64, Sheikh Zayed Road, near Emirates Hills, Dubai, United Arab Emirates; DOB 22 Jul 1951; POB Tashkent, Uzbekistan; National ID No. 03101200302034752 (United Arab Emirates); Passport CA1804389 (Uzbekistan); alt. Passport CA1890392 (Uzbekistan) (individual) [TCO]
1. SHAYBAZIAN, Lazar Gurgenovich (a.k.a. SHAYBAZYAN, Lazar); DOB 1 Apr 1966; Passport CA2485930 (Uzbekistan); alt. Passport CA2179793 (Uzbekistan) (individual) [TCO]

1. SHINODA, Kenichi (a.k.a. TSUKASA, Shinobu); DOB 25 Jan 1942; POB Oita Kyushu, Japan (individual) [TCO]

1. TAKAYAMA, Kiyoshi ; DOB 5 Sep 1947; POB Tsushimasi, Aichi Prefecture, Japan (individual) [TCO]

1. ZAYTSEV, Aleksey Alekseyevich (a.k.a. ZAITSEV, Alexei; a.k.a. ZAYTSEV, Alexey); DOB 7 Sep 1965; POB Leningrad, Russia; National ID No. 74914883 (United Arab Emirates); Passport 63-4604880 (Russia); alt. Passport 4103417473 (Russia); alt. Passport H2029462 (Ghana) (individual) [TCO]

1. YAMAGUCHI-GUMI (a.k.a. ROKUDAIME YAMAGUCHI-GUMI; a.k.a. SIXTH YAMAGUCHI-GUMI), 4-3-1 Shinohara-honmachi, Nada-Ku, Kobe City, Hyogo, Japan [TCO]”

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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.


Specially Designated Narcotics Trafficking Kingpin [SDNTK] and Transnational Criminal Organizations [TCO] Entries Changed on OFAC’s SDN List on February 23, 2012

February 23, 2012

Today, OFAC has changed [SDNTK] and [TCO] Entries on the Specially Designated Nationals List (SDN List):

The following [SDNTK][TCO] entries have been changed on OFAC’s SDN list:

KAMCHI BISHKEKSKIY (a.k.a. KOLBAEV, Kamchibek; a.k.a. KOLBAYEV, Kamchi; a.k.a KOLBAYEV, Kamchibek; a.k.a. KOLBAYEV, Kamchy; a.k.a. KOLBAYEV, Kamchybek Asanbekovich; a.k.a. “KOLYA-KYRGYZ”); DOB 3 Aug 1974; alt. DOB 1 Jan 1973; POB CholponAta, Kyrgyzstan; citizen Kyrgyzstan; Passport A0832532 (Kyrgyzstan) expires 17 Mar 2009 (individual) [SDNTK] -to- KAMCHI BISHKEKSKIY (a.k.a. KOLBAEV, Kamchibek; a.k.a. KOLBAYEV, Kamchi; a.k.a. KOLBAYEV, Kamchibek; a.k.a. KOLBAYEV, Kamchy; a.k.a. KOLBAYEV, Kamchybek Asanbekovich; a.k.a. “KOLYA-BISHKEKSKIY”; a.k.a. “KOLYA-KYRGYZ”), Bahar 1 Sector, C09-T02 Tower, Apartment 3203, Dubai 31672, United Arab Emirates; Volokolamskoye Shosse, House 15/22, Moscow, Russia; DOB 3 Aug 1974; alt. DOB 1 Jan 1973; POB Cholpon-Ata, Kyrgyzstan; citizen Kyrgyzstan; Passport A0832532 (Kyrgyzstan) expires 17 Mar 2009 (individual) [SDNTK] [TCO]

KOLBAEV, Kamchibek (a.k.a. KOLBAYEV, Kamchi; a.k.a. KOLBAYEV, Kamchibek; a.k.a. KOLBAYEV, Kamchy; a.k.a. KOLBAYEV, Kamchybek Asanbekovich; a.k.a. “KAMCHI BISHKEKSKIY”; a.k.a. “KOLYA-KYRGYZ”); DOB 3 Aug 1974; alt. DOB 1 Jan 1973; POB CholponAta, Kyrgyzstan; citizen Kyrgyzstan; Passport A0832532 (Kyrgyzstan) expires 17 Mar 2009 (individual) [SDNTK] -to- KOLBAEV, Kamchibek (a.k.a. KOLBAYEV, Kamchi; a.k.a. KOLBAYEV, Kamchibek; a.k.a. KOLBAYEV, Kamchy; a.k.a. KOLBAYEV, Kamchybek Asanbekovich; a.k.a. “KAMCHI BISHKEKSKIY”; a.k.a. “KOLYABISHKEKSKIY”; a.k.a. “KOLYA-KYRGYZ”), Bahar 1 Sector, C09-T02 Tower, Apartment 3203, Dubai 31672, United Arab Emirates; Volokolamskoye Shosse, House 15/22, Moscow, Russia; DOB 3 Aug 1974; alt. DOB 1 Jan 1973; POB Cholpon-Ata, Kyrgyzstan; citizen Kyrgyzstan; Passport A0832532 (Kyrgyzstan) expires 17 Mar 2009 (individual) [SDNTK] [TCO]

KOLBAYEV, Kamchi (a.k.a. KOLBAEV, Kamchibek; a.k.a. KOLBAYEV, Kamchibek; a.k.a. KOLBAYEV, Kamchy; a.k.a. KOLBAYEV, Kamchybek Asanbekovich; a.k.a. “KAMCHI BISHKEKSKIY”; a.k.a. “KOLYA-KYRGYZ”); DOB 3 Aug 1974; alt. DOB 1 Jan 1973; POB CholponAta, Kyrgyzstan; citizen Kyrgyzstan; Passport A0832532 (Kyrgyzstan) expires 17 Mar 2009 (individual) [SDNTK] -to- KOLBAYEV, Kamchi (a.k.a. KOLBAEV, Kamchibek; a.k.a. KOLBAYEV, Kamchibek; a.k.a. KOLBAYEV, Kamchy; a.k.a. KOLBAYEV, Kamchybek Asanbekovich; a.k.a. “KAMCHI BISHKEKSKIY”; a.k.a. “KOLYABISHKEKSKIY”; a.k.a. “KOLYA-KYRGYZ”), Bahar 1 Sector, C09-T02 Tower, Apartment 3203, Dubai 31672, United Arab Emirates; Volokolamskoye Shosse, House 15/22, Moscow, Russia; DOB 3 Aug 1974; alt. DOB 1 Jan 1973; POB Cholpon-Ata, Kyrgyzstan; citizen Kyrgyzstan; Passport A0832532 (Kyrgyzstan) expires 17 Mar 2009 (individual) [SDNTK] [TCO]

KOLBAYEV, Kamchibek (a.k.a. KOLBAEV, Kamchibek; a.k.a. KOLBAYEV, Kamchi; a.k.a. KOLBAYEV, Kamchy; a.k.a. KOLBAYEV, Kamchybek Asanbekovich; a.k.a. “KAMCHI BISHKEKSKIY”; a.k.a. “KOLYA-KYRGYZ”); DOB 3 Aug 1974; alt. DOB 1 Jan 1973; POB CholponAta, Kyrgyzstan; citizen Kyrgyzstan; Passport A0832532 (Kyrgyzstan) expires 17 Mar 2009 (individual) [SDNTK] -to- KOLBAYEV, Kamchibek (a.k.a. KOLBAEV, Kamchibek; a.k.a. KOLBAYEV, Kamchi; a.k.a. KOLBAYEV, Kamchy; a.k.a. KOLBAYEV, Kamchybek Asanbekovich; a.k.a. “KAMCHI BISHKEKSKIY”; a.k.a. “KOLYABISHKEKSKIY”; a.k.a. “KOLYA-KYRGYZ”), Bahar 1 Sector, C09-T02 Tower, Apartment 3203, Dubai 31672, United Arab Emirates; Volokolamskoye Shosse, House 15/22, Moscow, Russia; DOB 3 Aug 1974; alt. DOB 1 Jan 1973; POB Cholpon-Ata, Kyrgyzstan; citizen Kyrgyzstan; Passport A0832532 (Kyrgyzstan) expires 17 Mar 2009 (individual) [SDNTK] [TCO]

KOLBAYEV, Kamchy (a.k.a. KOLBAEV, Kamchibek; a.k.a. KOLBAYEV, Kamchi; a.k.a. KOLBAYEV, Kamchibek; a.k.a. KOLBAYEV, Kamchybek Asanbekovich; a.k.a. “KAMCHI BISHKEKSKIY”; a.k.a. “KOLYA-KYRGYZ”); DOB 3 Aug 1974; alt. DOB 1 Jan 1973; POB CholponAta, Kyrgyzstan; citizen Kyrgyzstan; Passport A0832532 (Kyrgyzstan) expires 17 Mar 2009 (individual) [SDNTK] -to- KOLBAYEV, Kamchy (a.k.a. KOLBAEV, Kamchibek; a.k.a. KOLBAYEV, Kamchi; a.k.a. KOLBAYEV, Kamchibek; a.k.a. KOLBAYEV, Kamchybek Asanbekovich; a.k.a. “KAMCHI BISHKEKSKIY”; a.k.a. “KOLYABISHKEKSKIY”; a.k.a. “KOLYA-KYRGYZ”), Bahar 1 Sector, C09-T02 Tower, Apartment 3203, Dubai 31672, United Arab Emirates; Volokolamskoye Shosse, House 15/22, Moscow, Russia; DOB 3 Aug 1974; alt. DOB 1 Jan 1973; POB Cholpon-Ata, Kyrgyzstan; citizen Kyrgyzstan; Passport A0832532 (Kyrgyzstan) expires 17 Mar 2009 (individual) [SDNTK] [TCO]

KOLBAYEV, Kamchybek Asanbekovich (a.k.a. KOLBAEV, Kamchibek; a.k.a. KOLBAYEV, Kamchi; a.k.a. KOLBAYEV, Kamchibek; a.k.a. KOLBAYEV, Kamchy; a.k.a. “KAMCHI BISHKEKSKIY”; a.k.a. “KOLYA-KYRGYZ”); DOB 3 Aug 1974; alt. DOB 1 Jan 1973; POB CholponAta, Kyrgyzstan; citizen Kyrgyzstan; Passport A0832532 (Kyrgyzstan) expires 17 Mar 2009 (individual) [SDNTK] -to- KOLBAYEV, Kamchybek Asanbekovich (a.k.a. KOLBAEV, Kamchibek; a.k.a. KOLBAYEV, Kamchi; a.k.a. KOLBAYEV, Kamchibek; a.k.a. KOLBAYEV, Kamchy; a.k.a. “KAMCHI BISHKEKSKIY”; a.k.a. “KOLYA-BISHKEKSKIY”; a.k.a. “KOLYA-KYRGYZ”), Bahar 1 Sector, C09-T02 Tower, Apartment 3203, Dubai 31672, United Arab Emirates; Volokolamskoye Shosse, House 15/22, Moscow, Russia; DOB 3 Aug 1974; alt. DOB 1 Jan 1973; POB Cholpon-Ata, Kyrgyzstan; citizen Kyrgyzstan; Passport A0832532 (Kyrgyzstan) expires 17 Mar 2009 (individual) [SDNTK] [TCO]

KOLYA-KYRGYZ (a.k.a. KOLBAEV, Kamchibek; a.k.a. KOLBAYEV, Kamchi; a.k.a. KOLBAYEV, Kamchibek; a.k.a. KOLBAYEV, Kamchy; a.k.a. KOLBAYEV, Kamchybek Asanbekovich; a.k.a. “KAMCHI BISHKEKSKIY”); DOB 3 Aug 1974; alt. DOB 1 Jan 1973; POB Cholpon-Ata, Kyrgyzstan; citizen Kyrgyzstan; Passport A0832532
(Kyrgyzstan) expires 17 Mar 2009 (individual) [SDNTK] -to- KOLYA-KYRGYZ (a.k.a. KOLBAEV, Kamchibek; a.k.a. KOLBAYEV, Kamchi; a.k.a. KOLBAYEV, Kamchibek; a.k.a. KOLBAYEV, Kamchy; a.k.a. KOLBAYEV, Kamchybek Asanbekovich; a.k.a. “KAMCHI BISHKEKSKIY”; a.k.a. “KOLYABISHKEKSKIY”), Bahar 1 Sector, C09-T02 Tower, Apartment 3203, Dubai 31672, United Arab Emirates; Volokolamskoye Shosse, House 15/22, Moscow, Russia; DOB 3 Aug 1974; alt. DOB 1 Jan 1973; POB Cholpon-Ata, Kyrgyzstan; citizen Kyrgyzstan; Passport A0832532 (Kyrgyzstan) expires 17 Mar 2009 (individual) [SDNTK] [TCO]

resulting in the following new [SDNTK][TCO] entries:

KOLYA-BISHKEKSKIY (a.k.a. KOLBAEV, Kamchibek; a.k.a. KOLBAYEV, Kamchi; a.k.a. KOLBAYEV, Kamchibek; a.k.a. KOLBAYEV, Kamchy; a.k.a. KOLBAYEV, Kamchybek Asanbekovich; a.k.a. “KAMCHI BISHKEKSKIY”; a.k.a. “KOLYA-KYRGYZ”), Bahar 1 Sector, C09-T02 Tower, Apartment 3203, Dubai 31672, United Arab Emirates; Volokolamskoye Shosse, House 15/22, Moscow, Russia; DOB 3 Aug 1974; alt. DOB 1 Jan 1973; POB Cholpon-Ata, Kyrgyzstan; citizen Kyrgyzstan; Passport A0832532 (Kyrgyzstan) expires 17 Mar 2009 (individual) [SDNTK] [TCO]

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

BELOBRYSYY (a.k.a. LEONTIEV, Vladislav; a.k.a. LEONTIEV, Vlantislav; a.k.a. LEONTYEV, Vadik; a.k.a. LEONTYEV, Vadim; a.k.a. LEONTYEV, Vladislav Vladimirovich; a.k.a. LEONTYEV, Vyacheslav; a.k.a. “BELYY”), AlFattan Building, Dubai, United Arab Emirates; DOB 5 Jul 1971; POB Gorky, Russia; alt. POB Caracas, Venezuela; National ID No. 60229551 (United Arab Emirates); Passport AB4065216 (Greece); alt. Passport H2214925 (Ghana); alt. Passport C1602418 (Venezuela) (individual) [TCO]

BELYY (a.k.a. LEONTIEV, Vladislav; a.k.a. LEONTIEV, Vlantislav; a.k.a. LEONTYEV, Vadik; a.k.a. LEONTYEV, Vadim; a.k.a. LEONTYEV, Vladislav Vladimirovich; a.k.a. LEONTYEV, Vyacheslav; a.k.a. “BELOBRYSYY”), Al-Fattan Building, Dubai, United Arab Emirates; DOB 5 Jul 1971; POB Gorky, Russia; alt. POB Caracas, Venezuela; National ID No. 60229551 (United Arab Emirates); Passport AB4065216 (Greece); alt. Passport H2214925 (Ghana); alt. Passport C1602418 (Venezuela) (individual) [TCO]

KHRISTOFOROV , Vasiliy (a.k.a. KHRISTOFOROV, Vasily Alexandrovich; a.k.a. “VASYA”; a.k.a. “VOSKRES”), Murjan 6 Sector, Tower D01-T03.1, Apartment 401, Dubai 39409, United Arab Emirates; DOB 12 Mar 1972; POB Gorky Oblast, Russia; National ID No. 76481815 (United Arab Emirates); Passport 63-7186356 (Russia) (individual) [TCO]

KHRISTOFOROV, Vasily Alexandrovich (a.k.a. KHRISTOFOROV , Vasiliy; a.k.a. “VASYA”; a.k.a. “VOSKRES”), Murjan 6 Sector, Tower D01-T03.1, Apartment 401, Dubai 39409, United Arab Emirates; DOB 12 Mar 1972; POB Gorky Oblast, Russia; National ID No. 76481815 (United Arab Emirates); Passport 63-7186356 (Russia) (individual) [TCO]

LEONTIEV, Vladislav (a.k.a. LEONTIEV, Vlantislav; a.k.a. LEONTYEV, Vadik; a.k.a. LEONTYEV, Vadim; a.k.a. LEONTYEV, Vladislav Vladimirovich; a.k.a. LEONTYEV, Vyacheslav; a.k.a. “BELOBRYSYY”; a.k.a. “BELYY”), Al-Fattan Building, Dubai, United Arab Emirates; DOB 5 Jul 1971; POB Gorky, Russia; alt. POB Caracas, Venezuela; National ID No. 60229551 (United Arab Emirates); Passport AB4065216 (Greece); alt. Passport H2214925 (Ghana); alt. Passport C1602418 (Venezuela) (individual) [TCO]

LEONTIEV, Vlantislav (a.k.a. LEONTIEV, Vladislav; a.k.a. LEONTYEV, Vadik; a.k.a. LEONTYEV, Vadim; a.k.a. LEONTYEV, Vladislav Vladimirovich; a.k.a. LEONTYEV, Vyacheslav; a.k.a. “BELOBRYSYY”; a.k.a. “BELYY”), Al-Fattan Building, Dubai, United Arab Emirates; DOB 5 Jul 1971; POB Gorky, Russia; alt. POB Caracas, Venezuela; National ID No. 60229551 (United Arab Emirates); Passport AB4065216 (Greece); alt. Passport H2214925 (Ghana); alt. Passport C1602418 (Venezuela) (individual) [TCO]

LEONTYEV, Vadik (a.k.a. LEONTIEV, Vladislav; a.k.a. LEONTIEV, Vlantislav; a.k.a. LEONTYEV, Vadim; a.k.a. LEONTYEV, Vladislav Vladimirovich; a.k.a. LEONTYEV, Vyacheslav; a.k.a. “BELOBRYSYY”; a.k.a. “BELYY”), AlFattan Building, Dubai, United Arab Emirates; DOB 5 Jul 1971; POB Gorky, Russia; alt. POB Caracas, Venezuela; National ID No. 60229551 (United Arab Emirates); Passport AB4065216 (Greece); alt. Passport H2214925 (Ghana); alt. Passport C1602418 (Venezuela) (individual) [TCO]

LEONTYEV, Vadim (a.k.a. LEONTIEV, Vladislav; a.k.a. LEONTIEV, Vlantislav; a.k.a. LEONTYEV, Vadik; a.k.a. LEONTYEV, Vladislav Vladimirovich; a.k.a. LEONTYEV, Vyacheslav; a.k.a. “BELOBRYSYY”; a.k.a. “BELYY”), AlFattan Building, Dubai, United Arab Emirates; DOB 5 Jul 1971; POB Gorky, Russia; alt. POB Caracas, Venezuela; National ID No. 60229551 (United Arab Emirates); Passport AB4065216 (Greece); alt. Passport H2214925 (Ghana); alt. Passport C1602418 (Venezuela) (individual) [TCO]

LEONTYEV, Vladislav Vladimirovich (a.k.a. LEONTIEV, Vladislav; a.k.a. LEONTIEV, Vlantislav; a.k.a. LEONTYEV, Vadik; a.k.a. LEONTYEV, Vadim; a.k.a. LEONTYEV, Vyacheslav; a.k.a. “BELOBRYSYY”; a.k.a. “BELYY”), Al-Fattan Building, Dubai, United Arab Emirates; DOB 5 Jul 1971; POB Gorky, Russia; alt. POB Caracas, Venezuela; National ID No. 60229551 (United Arab Emirates); Passport AB4065216 (Greece); alt. Passport H2214925 (Ghana); alt. Passport C1602418 (Venezuela) (individual) [TCO]

LEONTYEV, Vyacheslav (a.k.a. LEONTIEV, Vladislav; a.k.a. LEONTIEV, Vlantislav; a.k.a. LEONTYEV, Vadik; a.k.a. LEONTYEV, Vadim; a.k.a. LEONTYEV, Vladislav Vladimirovich; a.k.a. “BELOBRYSYY”; a.k.a. “BELYY”), Al-Fattan Building, Dubai, United Arab Emirates; DOB 5 Jul 1971; POB Gorky, Russia; alt. POB Caracas, Venezuela; National ID No. 60229551 (United Arab Emirates); Passport AB4065216 (Greece); alt. Passport H2214925 (Ghana); alt. Passport C1602418 (Venezuela) (individual) [TCO]

MANUILOV, Alexander (a.k.a. MANUYLOV, Aleksandr Leonidovich; a.k.a. MANUYLOV, Alexander; a.k.a. “SASHA SAMARSKIY”); DOB 3 Mar 1962; POB Russia; Passport 3056306 (Russia) (individual) [TCO]

MANUYLOV, Aleksandr Leonidovich (a.k.a. MANUILOV, Alexander; a.k.a. MANUYLOV, Alexander; a.k.a. “SASHA SAMARSKIY”); DOB 3 Mar 1962; POB Russia; Passport 3056306 (Russia) (individual) [TCO]

MANUYLOV, Alexander (a.k.a. MANUILOV, Alexander; a.k.a. MANUYLOV, Aleksandr Leonidovich; a.k.a. “SASHA SAMARSKIY”); DOB 3 Mar 1962; POB Russia; Passport 3056306 (Russia) (individual) [TCO]

RAKHIMOV, Gafur Akhmedovich (a.k.a. RAKHIMOV, Gafur-Arslanbek Akhmedovich; a.k.a. RAKHIMOV, Gofur-Arslonbek), The Meadows, Villa Number 64, Sheikh Zayed Road, near Emirates Hills, Dubai, United Arab Emirates; DOB 22 Jul 1951; POB Tashkent, Uzbekistan; National ID No. 03101200302034752 (United Arab Emirates); Passport CA1804389 (Uzbekistan); alt. Passport CA1890392 (Uzbekistan) (individual) [TCO]

RAKHIMOV, Gafur-Arslanbek Akhmedovich (a.k.a. RAKHIMOV, Gafur Akhmedovich; a.k.a. RAKHIMOV, Gofur-Arslonbek), The Meadows, Villa Number 64, Sheikh Zayed Road, near Emirates Hills, Dubai, United Arab Emirates; DOB 22 Jul 1951; POB Tashkent, Uzbekistan; National ID No. 03101200302034752 (United
Arab Emirates); Passport CA1804389 (Uzbekistan); alt. Passport CA1890392 (Uzbekistan) (individual) [TCO]

RAKHIMOV, Gofur-Arslonbek (a.k.a. RAKHIMOV, Gafur Akhmedovich; a.k.a. RAKHIMOV, GafurArslanbek Akhmedovich), The Meadows, Villa Number 64, Sheikh Zayed Road, near Emirates Hills, Dubai, United Arab Emirates; DOB 22 Jul 1951; POB Tashkent, Uzbekistan; National ID No. 03101200302034752 (United Arab Emirates); Passport CA1804389 (Uzbekistan); alt. Passport CA1890392 (Uzbekistan) (individual) [TCO]

SASHA SAMARSKIY (a.k.a. MANUILOV, Alexander; a.k.a. MANUYLOV, Aleksandr Leonidovich; a.k.a. MANUYLOV, Alexander); DOB 3 Mar 1962; POB Russia; Passport 3056306 (Russia) (individual) [TCO]

SHAYBAZIAN, Lazar Gurgenovich (a.k.a. SHAYBAZYAN, Lazar); DOB 1 Apr 1966; Passport CA2485930 (Uzbekistan); alt. Passport CA2179793 (Uzbekistan) (individual) [TCO]

SHAYBAZYAN, Lazar (a.k.a. SHAYBAZIAN, Lazar Gurgenovich); DOB 1 Apr 1966; Passport CA2485930 (Uzbekistan); alt. Passport CA2179793 (Uzbekistan) (individual) [TCO]

VASYA (a.k.a. KHRISTOFOROV , Vasiliy; a.k.a. KHRISTOFOROV, Vasily Alexandrovich; a.k.a. “VOSKRES”), Murjan 6 Sector, Tower D01-T03.1, Apartment 401, Dubai 39409, United Arab Emirates; DOB 12 Mar 1972; POB Gorky Oblast, Russia; National ID No. 76481815 (United Arab Emirates); Passport 63-7186356 (Russia) (individual) [TCO]

VOSKRES (a.k.a. KHRISTOFOROV , Vasiliy; a.k.a. KHRISTOFOROV, Vasily Alexandrovich; a.k.a. “VASYA”), Murjan 6 Sector, Tower D01-T03.1, Apartment 401, Dubai 39409, United Arab Emirates; DOB 12 Mar 1972; POB Gorky Oblast, Russia; National ID No. 76481815 (United Arab Emirates); Passport 63-7186356 (Russia) (individual) [TCO]

ZAITSEV, Alexei (a.k.a. ZAYTSEV, Aleksey Alekseyevich; a.k.a. ZAYTSEV, Alexey); DOB 7 Sep 1965; POB Leningrad, Russia; National ID No. 74914883 (United Arab Emirates); Passport 63-4604880 (Russia); alt. Passport 4103417473 (Russia); alt. Passport H2029462 (Ghana) (individual) [TCO]

ZAYTSEV, Aleksey Alekseyevich (a.k.a. ZAITSEV, Alexei; a.k.a. ZAYTSEV, Alexey); DOB 7 Sep 1965; POB Leningrad, Russia; National ID No. 74914883 (United Arab Emirates); Passport 63-4604880 (Russia); alt. Passport 4103417473 (Russia); alt. Passport H2029462 (Ghana) (individual) [TCO]

ZAYTSEV, Alexey (a.k.a. ZAITSEV, Alexei; a.k.a. ZAYTSEV, Aleksey Alekseyevich); DOB 7 Sep 1965; POB Leningrad, Russia; National ID No. 74914883 (United Arab Emirates); Passport 63-4604880 (Russia); alt. Passport 4103417473 (Russia); alt. Passport H2029462 (Ghana) (individual) [TCO]

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Written Testimony by Assistant Secretary for Terrorist Financing Daniel L. Glaser before the House Committee on Foreign Affairs

October 13, 2011

U.S. Department of the Treasury on October 13, 2011 released the following:

“Emerging Threats and Security in the Western Hemisphere: Next Steps for U.S. Policy”

Chairman Ros-Lehtinen, Vice Chair Gallegly, Ranking Member Berman, and distinguished members of this Committee, thank you for the opportunity to appear before you today to discuss emerging threats and security challenges in the Western Hemisphere, as well as priorities for U.S. security assistance and policy in the region. I am pleased to be here with my State Department colleagues, Ambassador Brownfield, Ambassador Goldberg, and Principal Deputy Assistant Secretary Jacobson.

The Western Hemisphere is a region of particular importance to the Treasury Department and critical to our mission of safeguarding the U.S. financial system. Our economic and financial institutions are fundamentally intertwined with those of our neighbors, most notably Mexico, a country confronting vicious transnational criminal organizations (TCOs) whose tentacles extend into the United States. Illicit financial activity in one corner of the region will inevitably find its way across our borders and into our financial institutions.

The Treasury Department possesses an array of tools and capabilities to target this illicit financial activity and safeguard our financial system from abuse. Our targeting capabilities include financial sanctions, the imposition of special regulatory measures and requirements, and engagement with at-risk financial institutions and jurisdictions. Along with our interagency colleagues, systemically we work bilaterally and through a variety of multilateral bodies to set anti-money laundering/combating the financing of terrorism (AML/CFT) international standards, work toward their universal adoption, and hold jurisdictions accountable for effective implementation.

Today, I’d like to talk to you about how we are employing these tools and capabilities to address illicit financial threats in the Western Hemisphere. I will start by discussing our efforts to disrupt, and ultimately dismantle the financial networks that support narcotics trafficking, terrorist groups and other illicit networks through targeted action, and then describe our systemic work to build a strong regional AML/CFT architecture.

Narcotics

The threat emanating from narcotics trafficking has been and remains the preeminent illicit finance challenge in the region. Perhaps more than any other illicit financial activity, narcotics-related money laundering places our financial institutions at risk and undermines the integrity of financial systems throughout the region. According to the National Drug Intelligence Center, Mexican and Colombian drug trafficking organizations “annually generate, move, remove and launder between $18 billion and $39 billion in wholesale distribution proceeds.” Much of this dirty money moves across our borders and transits our financial system.

Historically, economic sanctions have been our primary weapon to target the financial networks of drug trafficking organizations. Starting first in Colombia and then following the evolution of the narcotics industry to Mexico and beyond, the Treasury Department, through the Office of Foreign Assets Control (OFAC), has systematically targeted individuals and entities associated with some of the largest and most dangerous drug cartels operating in South America and Mexico, including – among others—the Cali and Medellin cartels; the Sinaloa, Gulf, Tijuana, and Juarez cartels; and the Los Zetas, La Familia Michoacana, and the Beltran Leyva Organization. Over the past several years, the United States has sanctioned nearly 2,300 individual and entities in Latin America involved in narcotics trafficking.

Our efforts against the Colombian cartels stand as one of our most successful programs to date. OFAC actions combined with other law enforcement efforts have disrupted over $1 billion worth of assets—in blockings, seizures, forfeitures, and the fail­ure of enterprises—and through the cooperation of the Colombian private sector, have dramatically restricted cartel access to the formal economy. These actions contributed to the broad Colombian and U.S. law enforcement pressure that led to the reversal of cartel fortune that we have witnessed over the last two decades in Colombia. Notwithstanding this success, Colombian DTOs, which still dominate the global production of cocaine, remain a priority for the Department, and we continue to attack their networks. In February, for example, we designated Colombian national Jorge Milton Cifuentes Villa and more than 70 associated individuals and entities operating in six countries as Specially Designated Narcotics Traffickers (SDNTs). Jorge Milton Cifuentes Villa, a dual Colombian-Mexican citizen, is a cocaine source of supply and money launderer for Sinaloa Cartel leader Joaquin “Chapo” Guzman Loera.

As the vertical integration of the hemispheric drug trade under the control of Colombian cartels gave way to a more segmented market progressively dominated by Mexican TCOs in the 1990s, the center of our counter narcotics sanctions efforts in the Western Hemisphere has increasingly shifted to Mexico. Since June 2000, close to 500 individuals and entities have been designated by OFAC under the Foreign Narcotics Kingpin Designation Act (the “Kingpin Act”), resulting in the blocking of approximately $16 million in financial assets in the United States and the exclusion of these persons from participation in the U.S. financial system. As of last month, $15.7 million of these blocked assets has subsequently been seized and forfeited by U.S. law enforcement.

Even as sanctions remain a centerpiece of the Treasury Department’s counternarcotics strategy, we recognize the importance of drawing upon additional tools to achieve a deeper and more lasting impact. This requires developing a specific understanding of the financial infrastructure of the Mexican TCOs. More detailed information about the key accountants, bookkeepers, attorneys and others who launder money for the cartels as well as the formal and informal financial institutions they use will allow for more varied and powerful disruption.

We have been working closely with our partners throughout the interagency to develop this information. Our partnership with the Drug Enforcement Administration (DEA), an organization which for many years has understood the importance of money laundering to drug cartels and whose information has proven vital to OFAC sanctions investigations, is especially close. The Treasury Department’s close collaboration with DEA is evidenced, most recently, by our joint work in support of the identification of the Lebanese Canadian Bank as a financial institution of primary money laundering concern under Section 311 of the USA PATRIOT Act for its role in facilitating a narcotics trafficking and money laundering network spanning South America, West Africa, and the Middle East. To build on the momentum of Treasury-DEA cooperation, I recently detailed a staff member to DEA’s Financial Operations Division to join the OFAC personnel who have been embedded in the unit for many years.

The Intelligence Community (IC) is also a key player in this effort. Treasury Assistant Secretary for Intelligence and Analysis, Leslie Ireland, recently named National Intelligence Manager for Threat Finance by the Director for National Intelligence, has made DTO finances an IC priority. As a result, we have already begun to see an increase in the quality and quantity of information and analysis on DTO finances.

But we alone cannot arrive at a comprehensive understanding of DTO financial networks. We need the active collaboration of our foreign counterparts who are on the front lines of the battle against the cartels. In this regard, the U.S.-Mexico Merida High-Level Consultative Group has played an important role in catalyzing enhanced bilateral cooperation. At its most recent meeting in April, the High Level Group identified money laundering as a priority security challenge and named the Treasury and Justice Departments as co-leads for the U.S. Government tasked with revitalizing bilateral efforts on this critical issue. We have taken this leadership role seriously. Over the past month, I have made two trips to Mexico to meet with counterparts to identify new avenues for enhanced information collection and sharing. In the process, I have met with senior officials in the Government of Mexico (GOM) policy, regulatory, law enforcement and intelligence sectors and I am confident that they share the view that as many tools of national power as possible must be brought to bear against TCO financial networks in a coordinated, bi-national manner. The Department of the Treasury’s efforts in this important endeavor have been assisted and advanced by the Department of Justice’s Asset Forfeiture and Money Laundering Section and Office of Overseas Prosecutorial Development, Assistance and Training both operationally as well as in building prosecutorial capacity.

We must also acknowledge the important steps the GOM is taking to counter drug-related money laundering. Consider, for example, the June 2010 Mexican regulations restricting U.S. dollar deposits aimed at drastically limiting the placement of U.S. origin drug money into the Mexican financial system. These regulatory changes were informed in part by joint analytical efforts between Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Mexican financial intelligence unit, the Unidad de Inteligencia Financiera (UIF), over multiple years to better understand U.S. dollar cash flows across our borders. Leading up to the publication of the regulations, the Mexican Finance Ministry coordinated with Treasury, and FinCEN was able to simultaneously publish an advisory for the U.S. financial system on the new regulations warning our institutions to be vigilant against the potential for a surge in money laundering activity in the U.S. in response to the Mexican restrictions. FinCEN and the UIF continue close coordination in monitoring the impact of these regulatory changes and potential diversion of funds, including to third countries.

Mexican regulators have also recognized the increased vulnerability of non-bank financial institutions—such as money remitters and informal exchange centers—as the formal financial system experiences the additional regulations and enhanced scrutiny. Accordingly, the GOM has made the significant decision to transfer supervision over these institutions from the Tax Administration to the Banking Commission which has greater supervisory expertise and resources. In 2012, the Banking Commission will take on this new responsibility and hopes to hire and train 80 new examiners to focus on this sector.

The GOM has taken other unprecedented steps to shore up its AML/CFT framework. Just recently, the Mexican Senate passed amendments to Mexico’s AML law which would impose strict caps—not simply reporting requirements—on the use of cash to purchase high value items, such as artwork (300,000 pesos/approx. $25,000), vehicles (400,000 pesos/approx. $34,000) and real estate (500,000 pesos/approx. $43,000). The goal of these measures is to encourage a shift away from a cash-based economy towards more efficient—and more traceable—electronic payments. Few jurisdictions in the world have been willing to implement such far-reaching and fundamental reforms. The Mexican congress’s lower house, the Chamber of Deputies, is expected to approve the measure in the next legislative session.

A comprehensive strategy to attack the financial resources of Mexican TCOs must not only include the U.S. and Mexico, but also the broader region. Central America, in particular Guatemala and Panama, serves as a critical narcotics transit and money laundering center. Indeed, preliminary information indicates that one of the primary effects of the regulatory tightening in Mexico is the displacement of bulk cash smuggling and money laundering activity in these two countries. With this in mind, I recently took a joint mission with counterparts from the Mexican Finance Ministry and Banking Commission—an unprecedented display of bilateral coordination and regional leadership—to Guatemala and Panama where we engaged host country authorities on these developments and on the importance of taking concerted action to undermine cartel financial networks. Going forward, both countries will remain priorities. It will be particularly important for Panama to be more proactive in addressing the significant deficiencies in its anti-money laundering controls and enforcement efforts. Taking steps in this direction, we are encouraged by recent efforts by Panama to increase financial transparency, in particular by entering into a tax information exchange agreement with the Treasury Department, and the accomplishment of being removed from the Organization for Economic Cooperation and Development’s grey list of tax havens on July 6, 2011.

Terrorism

Although the terrorist financing challenge in Latin America does not rise to the level of the narcotics-related financing threat, we take terrorist fundraising and facilitation seriously wherever it occurs. Within the Western Hemisphere, we have focused our efforts on Venezuela and the Tri-Border Area (TBA) of Brazil, Paraguay, and Argentina. Neither Al-Qa’ida nor its affiliates derive a significant amount of financial support from the region although we remain vigilant to this possibility.

Over the past several years, Treasury has demonstrated a strong commitment to exposing terrorist financing and facilitation activity in Venezuela. The nexus between the narco-terrorist group, the Revolutionary Armed Forces of Colombia (FARC), one of the few organizations in the world bearing the dubious distinction of being both a designated “kingpin” and “specially designated global terrorist,” and Venezuelan government officials, has been a particular focus. In September 2008, OFAC designated three senior Venezuelan security officials under the Kingpin Act (two of whom were in office at the time of designation) for, among other things, protecting drug shipments from seizure by Venezuelan anti-narcotics authorities, providing weapons and official Venezuelan government identification to the FARC and pushing for greater cooperation between the Venezuelan government and the FARC. Other significant designations include the FARC International Commission representative in Venezuela.

Although not as extensive as its involvement with the FARC, there are also troubling ties between Caracas and Hezbollah which we have sought to expose through targeted sanctions. For instance, in June 2008, OFAC designated two key Venezuelan supporters of Hezbollah under Executive Order 13224, which targets terrorists, those individuals or entities owned or controlled by or acting for or on behalf of terrorists, and those providing financial, material, or technological support to terrorists or acts of terrorism. One of these individuals, Ghazi Nasr al-Din, used his position as a senior Venezuelan diplomat to provide financial support to Hezbollah. The other, Fawzi Kan’an, the owner of two Caracas-based travel agencies, serves as a key facilitator and fundraiser for Hezbollah officials.

Hezbollah has also engaged in significant fundraising and facilitation activity in the TBA. Starting in 2006, we have systematically designated over a dozen individuals in the area as well as several entities for providing financial support to Hezbollah leadership in Lebanon. Most recently, in December 2010, we imposed sanctions against Hezbollah’s chief representative in South America responsible for oversight of the group’s counterintelligence activities in the TBA, Bilal Mohsen Wehbe.

We have not relied solely on sanctions under the Kingpin Act and EO 13224 to disrupt narco-trafficking and terrorist financing networks in the Western Hemisphere. In February 2011, for example, we identified the Lebanese Canadian Bank under Section 311 of the USA PATRIOT Act as an institution of primary money laundering concern. This action dealt a significant blow to a transnational money laundering network with a significant presence in the Western Hemisphere. Hezbollah derived financial support from this network which was controlled by OFAC-designated Lebanese Kingpin, Ayman Joumaa.

Iran

While it is in the interests of an increasingly isolated Iran to seek expansion of its economic and financial ties to Latin America, the reality is that, to date, Iran has failed to establish a meaningful foothold in the region. When Iran has managed to make inroads, we have been quick to act. Most notably, we designated Banco Internacional de Desarollo, a Venezuela-based subsidiary of the Export Development Bank of Iran. We subsequently worked to secure its designation by the European Union and Australia, thereby significantly curtailing its access to the international financial system. We have also proactively engaged with governments and private sector officials throughout the region to warn against the risks of doing business with Iran. For example, in August 2010 then Assistant Secretary David Cohen traveled to Brazil and Ecuador to discuss implementation of the financial provisions of United Nations Security Council Resolution 1929 and implications for foreign financial institutions of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA).

Systemic Reform Efforts

Equally important as our targeted measures is Treasury’s work to build a robust domestic and international AML/CFT framework to safeguard the financial sector. Through the Financial Action Task Force (FATF) and its associate regional bodies in the Western Hemisphere, we have been working for many years to set anti-money laundering and counter-terrorist financing standards and best practices and hold countries in the region accountable for their implementation. Uneven implementation creates vulnerabilities in the regional regulatory and enforcement architecture that can be–and, indeed, have been–exploited by illicit networks, in particular DTOs. Using a methodology jointly developed by the FATF, International Monetary Fund (IMF), and World Bank, every country in the region, with the notable exception of Cuba, has been or is scheduled to be assessed against the international AML/CFT standards. These assessments are published and highlight weaknesses in each jurisdiction alongside recommendations for remedying those deficiencies.

Based in part on a G-20 Leaders’ call, the FATF has instituted an additional review process that publicly identifies jurisdictions that fail to meet international AML/CFT standards and may therefore pose a risk to the international financial system. I serve as co-chair of this process within the FATF. Jurisdictions that have been identified by this process must commit to an Action Plan of ambitious reforms. If the reform timelines specified in the Action Plan are not met, the FATF will issue increasingly strong public warnings, potentially culminating in a specific call for regulatory countermeasures from member countries. In an age when global financial institutions rely upon the FATF in their assessments of jurisdictional risk, this process has served as a great catalyst for reform in previously recalcitrant countries.

Within the Western Hemisphere to date, ten jurisdictions have been publicly identified by this process: Antigua and Barbuda, Argentina, Bolivia, Cuba, Ecuador, Honduras, Nicaragua, Paraguay, Trinidad and Tobago, and Venezuela. More than half of these countries have passed important legislation that strengthens their AML/CFT regimes as a direct response to this process. For example, both Honduras and Paraguay have passed legislation criminalizing terrorism finance, which likely would not have happened so quickly without the encouragement from this FATF process.

In addition to our multilateral efforts, Treasury maintains an active technical assistance program managed by the Office of Technical Assistance (OTA) to help jurisdictions implement AML/CFT reforms. My office works with OTA which has recently targeted AML/CFT assistance to a number of high risk jurisdictions within Latin America. We currently have resident advisors from our Economic Crimes Team (ECT) embedded with host governments in Costa Rica, Guatemala, Honduras, and Paraguay. Additionally, ECT Advisors continue to work in Haiti in a robust technical assistance program designed to build up and strengthen that country’s AML/CFT capacity. These advisors are working to improve preventative, enforcement and prosecution pillars of their AML/CFT regimes and to ensure their ability to seize and forfeit the proceeds and instrumentalities of crime. Technical assistance provided by ECT comprises institution building, legislative reform, outreach to AML/CFT stakeholders in the private sector, and capacity building all designed to enable these countries to bring money launderers and drug traffickers to justice using their own authorities and resources.

We recognize that it is not enough for the Department of the Treasury to solely work with our government counterparts in these multilateral and bilateral forums. A fundamental component of our approach to combating illicit finance is sustained engagement with the private sector on these issues. Our Department has reached out to the private sector around the world on illicit finance threats, and the Western Hemisphere is no exception. For example, an important initiative by my office is the U.S.-Latin America Private Sector Dialogue, or PSD. We are currently planning the sixth iteration of this dialogue, to be held in February 2012 in conjunction with the Florida International Bankers Association (FIBA) Annual Anti-Money Laundering and Compliance Conference. We launched the U.S.-Latin America PSD in June 2006 to establish a permanent dialogue between the United States and Latin American financial sectors. This initiative, which began as a roundtable discussion here in Washington, D.C., seeks to achieve better relations and coordination between correspondent financial institutions in these regions. Over 200 participants from approximately 20 different countries representing regulators and financial institutions in the United States and Latin America attend this event on an annual basis. Indeed, this forum has become a place where both U.S. and Latin American financial institutions can lay out their concerns with each other and seek to establish better controls to mitigate risk.

Conclusion

The Department of the Treasury recognizes that the Western Hemisphere presents persistent and unique security threats to our financial system. Under Secretary Cohen and I are committed to prioritizing the Department’s work in this region. Our efforts to combat these threats will persist and we will continue to find unique and innovative ways to disrupt and dismantle illicit financial networks. We will also continue our efforts to build consensus with our regional partners to develop our hemispheric approach to ensuring that all countries in the region build strong systems to counter these threats.”

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.


Transnational Criminal Organizations [TCO] Entries Changed on OFAC’s SDN List on September 1, 2011

September 1, 2011

As of today, OFAC has changed Transnational Criminal Organizations [TCO] Entries on the Specially Designated Nationals List (SDN List):

The following Transnational Criminal Organizations [TCO] entries have been changed on OFAC’s SDN list:

BORYOKUDAN (a.k.a. GOKUDO; a.k.a. YAKUZA), Brazil; Japan; Australia; Hong Kong; Canada; Japan; Korea, South; Philippines; Indonesia; Russia; Thailand; United Kingdom; China; Taiwan; Malaysia; Singapore; UU [TCO] -to- BORYOKUDAN (a.k.a. GOKUDO; a.k.a. YAKUZA), Japan [TCO]

GOKUDO (a.k.a. BORYOKUDAN; a.k.a. YAKUZA), Brazil; Japan; Australia; Hong Kong; Canada; Japan; Korea, South; Philippines; Indonesia; Russia; Thailand; United Kingdom; China; Taiwan; Malaysia; Singapore; UU [TCO] -to- GOKUDO (a.k.a. BORYOKUDAN; a.k.a. YAKUZA), Japan [TCO]

YAKUZA (a.k.a. BORYOKUDAN; a.k.a. GOKUDO), Brazil; Japan; Australia; Hong Kong; Canada; Japan; Korea, South; Philippines; Indonesia; Russia; Thailand; United Kingdom; China; Taiwan; Malaysia; Singapore; UU [TCO] -to- YAKUZA (a.k.a. BORYOKUDAN; a.k.a. GOKUDO), Japan [TCO]

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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 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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