US Senate Passes New Iran Sanctions Bill

May 22, 2012

The Wall Street Journal on May 22, 2012 released the following:

“By Samuel Rubenfeld

The U.S. Senate passed on Monday night — by voice vote — new sanctions on Iran ahead of diplomatic talks about Tehran’s nuclear program.

The legislation, which was blocked last Thursday by Republicans seeking minor language tweaks despite overwhelming support, sailed through Monday on the voice vote after doing the same in committee. The bill, among other things, imposes sanctions on the parent companies of foreign subsidiaries violating sanctions. It also requires the disclosure of all sanctionable activity to the Securities and Exchange Commission.

Lawmakers have been on the offensive to punish Iran for its nuclear program, which Tehran says is peaceful.

“Iran’s Supreme Leader has a choice: Either come to Baghdad with a real plan to terminate Iran’s nuclear program or we’ll make our own plan – through sanctions or other necessary measures — to ensure that Iran fails to achieve its nuclear ambitions,” said Sen. Bob Menendez (D., N.J.) in a statement.

The Senate-passed legislation still has to be reconciled with a House bill before it reaches President Barack Obama’s desk. It comes on top of sanctions legislation signed into law last year that targets anyone doing business with Iran’s central bank, which routes most of its oil transactions.

Those sanctions were implemented in early February via executive order, and a guidance and a rule were issued by the Treasury Department later that month. In April, the White House announced a new program that makes it easier to go after Iran sanctions evaders.

The bill passed Monday night broadens the list of available programs under which sanctions can be imposed on Iranian individuals and entities.

It also requires the U.S. to determine whether the National Iranian Oil Co. and National Iranian Tanker Co. are agencies of the country’s Revolutionary Guard Corps, and then impose sanctions on anyone facilitating sanctions for either entity.”

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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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FACT SHEET: New Executive Order Targeting Foreign Sanctions Evaders

May 2, 2012

U.S. Department of the Treasury on May 1, 2012 released the following:

“WASHINGTON – Today the President signed an Executive Order (E.O.), “Prohibiting Certain Transactions with and Suspending Entry into the United States of Foreign Sanctions Evaders with Respect to Iran and Syria,” providing the U.S. Treasury Department with a new authority to tighten further the U.S. sanctions on Iran and Syria.

This E.O. targets foreign individuals and entities that have violated, attempted to violate, conspired to violate, or caused a violation of U.S. sanctions against Iran or Syria, or that have facilitated deceptive transactions for persons subject to U.S. sanctions concerning Syria or Iran. With this new authority, Treasury now has the capability to publicly identify foreign individuals and entities that have engaged in these evasive and deceptive activities, and generally bar access to the U.S. financial and commercial systems.

“The foreign sanctions evaders E.O. provides Treasury additional means to impose serious consequences on foreign persons who seek to evade our sanctions and undermine international efforts to bring pressure to bear on the Iranian and Syrian regimes. Whoever tries to evade our sanctions does so at the expense of the people of Syria and Iran, and they will be held accountable,” said Under Secretary for Terrorism and Financial Intelligence David S. Cohen.

Upon Treasury’s identification and listing of a foreign sanctions evader, U.S. persons will generally be prohibited from providing to, or procuring from, the sanctioned party goods, services, or technology, effectively cutting the evader off from the U.S. marketplace. This provides Treasury with a powerful new tool to prevent, deter, and respond to the risks posed by sanctions evaders to the U.S. and global financial system. It also will help prevent U.S. persons from unwittingly engaging in transactions with foreign individuals and entities that pose a particular risk of running afoul of U.S. sanctions concerning Iran or Syria.

The foreign sanctions evaders E.O. is the latest in a broad-based and escalating series of steps taken by the United States and its international partners targeting the governments of Iran and Syria with respect to their abuse of human rights, support for terrorism, and proliferation and development of weapons of mass destruction. The foreign sanctions evaders E.O. follows by one week the Executive Order Blocking The Property And Suspending Entry into the United States of Certain Persons with Respect to Grave Human Rights Abuses by the Governments of Iran and Syria via Information Technology (the “GHRAVITY E.O.”), which targeted the provision and use of information and communications technology to facilitate computer or network disruption, monitoring, or tracking that could assist in or enable serious human rights abuses by or on behalf of the Government of Iran or the Government of Syria.

The United States has already blocked (i.e., frozen) property and interests in property of the Government of Iran, its agencies and instrumentalities, and all Iranian financial institutions, including the Central Bank of Iran. In all, the Treasury Department has announced over 400 Iran-related designations and identifications of individuals and entities supporting various illicit actions of the Government of Iran, including human rights abuses, support for terrorism, and WMD proliferation. For more information, please see http://www.treasury.gov/ofac.

Similarly, the Administration has blocked the property and interests in property of the Government of Syria and its agencies and instrumentalities, including the Central Bank of Syria. The Treasury Department also has designated major Syrian financial institutions, including the Commercial Bank of Syria. In all, the Treasury Department has designated more than 60 individuals and entities supporting Syria’s human rights abuses and other repressive policies. For more information, please see http://www.treasury.gov/ofac.”

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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 questions, but want to be anonymous?

Free Skype Tel: +1.202.470.3427, OR

Free Skype call: mcnabb.mcnabbassociates

           Office Locations

Email:


Obama Signs Executive Order Putting Tougher Sanctions on Iran

February 7, 2012

The Cypress Times on February 6, 2012 released the following:

“WASHINGTON, DC – Today, President Obama signed an Executive Order (E.O.) that takes a number of actions in furtherance of the Administration’s Iran sanctions program, including measures to implement section 1245 of the National Defense Authorization Act (NDAA). Among other things, the E.O. freezes all property of the Central Bank of Iran and all other Iranian financial institutions, as well as all property of the Government of Iran, further tightening the already broad-based and stringent U.S. sanctions on Iran.

These actions underscore the Administration’s resolve to hold the Iranian regime accountable for its failure to meet its international obligations. Iran now faces an unprecedented level of pressure due to intensified sanctions applied by the United States and complementary actions by many others around the world. The new E.O. issued today reemphasizes this Administration’s message to the Government of Iran – it will face ever-increasing economic and diplomatic pressure until it addresses the international community’s well-founded and well-documented concerns regarding the nature of its nuclear program.

Additional information describing the implementation of section 1245 of the NDAA pursuant to the authorities delegated under this E.O. will be made available in the near term.

Sanctions under the New Executive Order:

On February 5, President Obama signed a new E.O. effective at 12:01 a.m. on February 6, that blocks (i.e., “freezes”) all property of the Government of Iran as well as all property of Iranian financial institutions, including the Central Bank of Iran.

1. The E.O. blocks all property and interests in property of the Government of Iran, the Central Bank of Iran and all Iranian financial institutions (regardless of whether the financial institution is part of the Government of Iran) that are in the United States, that come within the United States, or that come within the possession or control of U.S. persons. Previously, U.S. persons were required to “reject,” rather than “block,” Iranian transactions.

  • Under the order, the Government of Iran, the Central Bank of Iran, and all Iranian financial institutions are now blocked (i.e. their assets within the jurisdiction of U.S. persons are frozen).
  • The U.S. sanctions in place since 1995 have required most transactions involving the Government of Iran, the Central Bank of Iran and all Iranian financial institutions to be rejected – that is, they could not pass through the U.S. financial system, but instead were turned back. Under the new E.O., transactions involving the Government of Iran, the Central Bank of Iran and all Iranian financial institutions that previously would have been rejected will now be blocked.
  • All entities that meet the existing definition of “Government of Iran,” such as Iranian ministries, state-owned entities and commercial firms owned or controlled by the Government of Iran, are blocked. This includes entities bearing the [IRAN] tag on the Treasury Department’s Office of Foreign Assets Control’s (OFAC) List of Specially Designated Nationals and Blocked Persons (SDN List). Transactions by U.S. persons involving such entities are now blocked unless exempt or otherwise authorized. OFAC will continue to update the SDN List and may add, delete, or edit existing entries as appropriate.
  • The E.O. does not change the sanctions that may be applied against foreign financial institutions engaging in arms-length transactions with certain Iranian financial institutions, including the Central Bank of Iran. Those foreign financial institutions remain at risk of U.S. sanctions if they engage in certain significant financial transactions with the Central Bank of Iran or certain other designated Iranian financial institutions pursuant to the NDAA, or the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA).

2. Treasury is issuing general licenses to maintain existing authorizations for certain transactions that advance U.S. foreign policy interests.

  • Persons who currently use general or specific licenses from OFAC for transactions involving the Government of Iran or Iranian financial institutions should consult the OFAC website for new general licenses and other information on whether those transactions remain authorized under the new E.O.

Delegations of Authority under the New Executive Order:

The E.O. also delegates other authorities provided in section 1245(d) of the NDAA.

  • The E.O. delegates a number of other authorities provided in section 1245(d) of the NDAA, primarily to the Departments of the Treasury and State. These delegations will facilitate the implementation of section 1245 of the NDAA.
  • Additional information describing the implementation of the NDAA under these delegated authorities will be made available in the near term.”

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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.