“OFAC Issues New Guidance Regarding Entities Owned by one or More Designated Parties”

August 19, 2014

The National Law Review on August 18, 2014 released the following:

“On August 13, 2014, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new guidance advising that it has changed its policy governing whether entities that are owned by individuals or entities designated under Executive Orders and regulations administered by OFAC, but are not themselves designated, are also subject to U.S. sanctions.

Pursuant to this new guidance, any entity that is owned 50 percent or more in the aggregate, directly or indirectly, by one or more parties on OFAC’s Specially Designated Nationals and Blocked Persons List (“SDN List”) is subject to blocking.1 This is a significant departure from prior OFAC guidance that it was not necessary to aggregate the ownership interests of separate SDN-Listed parties to determine whether a non-listed entity was considered to be blocked.

The new “50 Percent Rule” provides that, effective immediately, the property and interests in property of any entity owned 50 percent or more in the aggregate, directly or indirectly, by persons designated on the SDN List that are, or come into, the United States or the possession of control of a U.S. person are blocked and cannot be dealt in absent licensing or other authorization from OFAC. This means that U.S. persons are effectively prohibited from engaging in any dealings with any entity directly or indirectly owned 50 percent or more in the aggregate by one or more blocked parties regardless of whether such entity is itself designated on the SDN List.

In Frequently Asked Questions (“FAQs”) that OFAC issued on August 14 clarifying the scope of the new 50 Percent Rule, OFAC has provided that this new aggregation test also applies in determining whether entities that are not on the Russian Sectoral Sanctions Identifications (“SSI”) List are subject to the sanctions that apply to the SSI-Listed Russian banks and oil companies. Entities on the SSI List, and entities owned 50 percent or more in the aggregate by such SSI-Listed entities, are not subject to comprehensive blocking measures. Rather, they are subject to a more limited set of restrictions related to new debt with a maturity of longer than 90 days and, in the case of the SSI- Listed banks, new equity, in either case issued by, on behalf of, or for such an entity. For more information on the full scope of SSI List restrictions, please see our prior E-Alert dated July 30, 2014.

THE SCOPE OF THE 50 PERCENT RULE

OFAC’s FAQs offer the following additional guidance concerning the application of the new 50Percent Rule:

1 Certain OFAC sanctions programs are broader and also target entities that are controlled by sanctioned parties. For example, the Iranian Transactions and Sanctions Regulations apply to entities that are owned or controlled by the government of Iran. See 31 C.F.R. §§ 560.304 and 560.313. The 50 Percent Rule’s focus on ownership does not limit the broader scope of these sanctions programs.

The 50 Percent Rule applies only to ownership interests, not control. According to OFAC, “[a]n entity that is controlled (but not owned 50 percent or more) by one or more blocked persons is not considered automatically blocked” pursuant to the 50 Percent Rule. Nonetheless, companies should proceed with caution when considering a transaction with an entity that one or more blocked parties may control because OFAC could add that entity to the SDN List at some point in the future.

Consistent with prior guidance that OFAC has issued, companies should be careful not to negotiate, enter into contracts, or process transactions that involve a blocked person when the blocked person is acting on behalf of a non-blocked entity. OFAC sanctions “prohibit transactions involving, directly or indirectly, a blocked person…even if the blocked person is acting on behalf of a non-blocked entity.” This includes, for example, situations in which a blocked person signs a contract on behalf of a non-blocked entity.

Indirect ownership refers to “ownership of shares of an entity through another entity or entities that are 50 percent or more owned in the aggregate by the blocked person(s).” This means that if Blocked Person X owns 50 percent of Entity A, and Entity A owns 50 percent of Entity B, then both Entity A and B are blocked — Entity A because it is directly owned 50 percent by Blocked Person X and Entity B because it is owned 50 percent by blocked Entity A. Similarly, if Blocked Person X owns 50 percent of Entity A and 10 percent of Entity B, and Entity A also owns 40 percent of Entity B, then Entity B is considered as blocked based on the aggregate 50 percent ownership of Entity B by two blocked parties.

By contrast, indirect ownership does not apply at all where a blocked party owns less than a 50 percent interest in the intermediate entity. Thus, if Blocked Person X owns only 25 percent of Entity A and 25 percent of Entity B, no matter how large an interest Entities A and B hold in Entity C, Entity C will not be considered blocked. This is because Blocked Person X’s 25 percent ownership of each of Entity A and Entity B falls short of 50 percent. Accordingly, neither Entity A nor Entity B is blocked and, for purposes of the 50 Percent Rule, Blocked Person X is not considered to indirectly own any of Entity C as a result of its minority ownership of Entities A or B.

While all of the OFAC examples in the FAQs address circumstances involving a single Blocked Person, the guidance would apply more broadly. For example, if Blocked Person X owns 50 percent of Entity A, and Entity A owns 25 percent of Entity B, and Blocked Person Y owns 50 percent of Entity C, which also owns 25 percent of Entity B, then the combination of the indirect ownership and 50 Percent Rule requirements may make Entity B a blocked person. While the FAQs do not address this situation, we believe OFAC would consider Entity B to be a blocked person since Entities A and C would each be considered blocked entities because of their 50 percent ownership by blocked persons, and in the aggregate they own 50 percent of Entity B.

Companies likely will need to undertake significant additional due diligence in order to collect the information about direct and indirect ownership interests that is necessary to make these complex calculations and to aggregate ownership information across multiple levels of a corporate structure. Indeed, OFAC urges companies considering a transaction to conduct “appropriate due diligence” on the involved entities in order to determine relevant ownership stakes.

Under certain limited circumstances, it may be possible for one or more blocked persons to divest their ownership stake in an entity in order to ensure that the combined ownership by blocked persons in the entity is less than 50 percent. However, these actions must be undertaken entirely outside of U.S. jurisdiction and without the involvement of any U.S. persons. Companies also should be careful to avoid “sham transactions” by conducting sufficient due diligence to be confident that any purported divestment actually occurred before they enter into any dealings with entities that were previously owned 50 percent or more by one or more designated parties.

If the aggregate ownership of blocked parties in an entity falls below 50 percent due to the actions of one or more of the blocked parties, including the entity itself, any property or interests in property that were previously in the United States or the possession or control of a U.S. person remain blocked and cannot be dealt in absent licensing or other authorization from OFAC. This is because OFAC does not recognize the unlicensed transfer of blocked property in the United States or in the possession or control of a U.S. person. This position imposes an additional layer of due diligence as it suggests that U.S. persons may need to conduct a retrospective analysis of the property of entities that they learn are minority owned by a blocked party in order to ensure that the entity was not previously owned 50 percent or more in the aggregate by blocked parties.”

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

August 29, 2012

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

The following [SDNTK] entries have been removed:

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

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

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

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

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

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

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Douglas McNabb – McNabb Associates, P.C.’s
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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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Group Seeks Suspension of Iran From I.M.F.

May 2, 2012

The New York Times on May 1, 2012 released the following:

“By RICK GLADSTONE

An American advocacy group that has successfully pushed to isolate Iran economically through sanctions and business boycotts opened a new front in that effort on Tuesday, seeking to pressure the International Monetary Fund to withdraw all its holdings in Iran’s central bank or to suspend Iranian membership.

The advocacy group, United Against Nuclear Iran, also castigated the fund’s managing director, Christine Lagarde, over what it called her inappropriate compliments for Iran’s central bank, known as Bank Markazi, and its governor, Mahmoud Bahmani, at the meetings of the International Monetary Fund and World Bank in Washington last month. Ms. Lagarde had described the Iranian government’s effort to eliminate costly economic subsidies as a constructive step worthy of emulation, and the compliments were widely reported in Iran’s state-run media.

“The I.M.F. should not be hosting Iranian delegations in the U.S. and elsewhere, and Ms. Lagarde should stop lavishing praise on Iran and Bank Markazi,” the chief executive of United Against Nuclear Iran, Mark D. Wallace, said in a statement announcing its new effort.

Iran is one of the earliest members of the 188-nation I.M.F., founded in the aftermath of World War II to help strengthen monetary cooperation and stability through lending and economic data-gathering. Although Iran has not done any financial transactions with the I.M.F. since January 1984, according to the I.M.F. Web site, membership is regarded as a valued symbol of international legitimacy and respect.

In a letter to Ms. Lagarde dated April 26, Mr. Wallace, a former American diplomat at the United Nations, said the I.M.F. should close what he described as an I.M.F. account worth more than $1 billion held in the central bank, which has been penalized by the United States and European Union. Mr. Wallace said the bank had been shown to be untrustworthy, violating the I.M.F.’s own standards and safeguards.

“I don’t have a grudge with the good people of the I.M.F.,” Mr. Wallace said in a telephone interview. But, he said, “it can’t be business as usual anymore.”

William Murray, a spokesman for the I.M.F. in Washington, said in a statement that the fund’s holdings in Iran’s central bank are part of the arrangements made with any member, and that the account is denominated in Iranian currency, not dollars.

“There is nothing in the E.U. or U.S. sanctions regimes that is inconsistent with these arrangements,” he said. As for the call for Iran’s suspension, Mr. Murray said, “This is a matter that is best taken up with the fund’s member countries. We have no comment.”

Under Article 26 of the I.M.F. Articles of Agreement, suspension of an I.M.F. member’s voting rights requires approval from a 70 percent majority of the total voting power among the other members, which is weighted partly according to their economic size.

A Treasury Department spokesman in Washington, John Sullivan, said that both the United States and the European Union regarded the I.M.F. as exempt from American and European sanctions on Iran’s central bank.

There was no immediate comment from Iran. But the effort by Mr. Wallace’s group to pressure the I.M.F. could represent a new challenge to Iran, coming as all sides in the protracted dispute over Iran’s uranium enrichment program have been toning down inflammatory rhetoric in recent weeks and speaking with a measure of optimism about a possible diplomatic resolution.

Talks held in Turkey last month were described as positive by Iran and the group of six world powers seeking to stop Iran from enriching uranium that could be used to make nuclear weapons. But Iranian officials have also said the Western sanctions should be eased as a sign of good will, and have hinted their mood could darken if new efforts to isolate Iran were introduced. Talks are set to resume in Baghdad on May 23.”

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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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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:

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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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White House expands reach of sanctions on Syria, Iran

May 1, 2012

Miami Herald on May 1, 2012 released the following:

“BY KEVIN G. HALL
MCCLATCHY NEWSPAPERS
WASHINGTON — The Obama administration on Tuesday granted the Treasury Department authority to blacklist foreign nationals and companies that help Iran and Syria evade U.S. and international sanctions.

President Barack Obama signed an executive order and notified congressional leaders that he had given Treasury expanded powers to thwart the evasion of U.S. sanctions. These powers give the accused little chance of seeing the evidence against them, but they don’t run afoul of constitutional due-process rights since they apply to foreign entities.

“I have determined that efforts by foreign persons to engage in activities intended to evade U.S. economic and financial sanctions with respect to Iran and Syria undermine our efforts,” the president said in a letter to House Speaker John Boehner, R-Ohio, and Senate Majority Leader Harry Reid, D-Nev.

The administration hopes that the ever-tightening financial sanctions will force Iran to abandon its nuclear ambitions and the Syrian government to end its oppression of rebels who seek to oust it.

The new executive order allows Treasury to prohibit accused foreign nationals or companies from traveling to the United States and permits the agency to forbid U.S. companies to deal with them.

Treasury and its Office of Foreign Assets Control already have similar powers to lock companies or individuals out of the U.S. banking system, thus effectively shutting them out of the global system. Tuesday’s action was aimed at smaller companies that are helping Iran and Syria skirt the sanctions.

“Both countries are seeking to use non-bank financial institutions,” said a senior Treasury official, who briefed reporters on the condition of anonymity in order to speak freely. The official cited currency exchange houses or trading firms that don’t have a U.S. presence and fly under the radar in assisting Iran and Syria.

The agency didn’t sanction anyone with the announcement Tuesday.

“That will come in due course,” the official said. He added that foreign companies that are abetting Syria and Iran are “put on clear notice that the United States government has a new tool at its disposal to disrupt that activity.”

The official described the new measure as “more nimble and agile.” He said it targeted entities that were “in the cracks out there, where they are not engaged in behavior that would rise to the level of a (prior) designation, but are not readily susceptible to an enforcement action … because they have no U.S. presence.”

Tuesday’s announcement followed months of increasing financial pressure on Iran, including a move in March by the European Union to prevent dozens of Iranian banks from accessing the international system through which banks transfer money electronically. Treasury also has sanctioned most of the leaders of the Iranian banking, shipping and military sectors, as well as most of the family members of Syrian dictator Bashar Assad and his political allies.

For those accused under the new executive order, there won’t be the sorts of due process protections that U.S. citizens or companies are afforded. Treasury officials will share only unclassified information with the accused, meaning they will often be unable to see the information that’s leading to their accusal.

As with the financial provisions of the controversial Patriot Act, the accused can challenge under the Administrative Procedure Act, which covers not the content of the allegation but rather the process. A federal judge, however, would have access to the classified portions of the case should the accused seek legal redress.

“There is certainly a lot of room for abuse,” said Ilya Shapiro, a senior fellow in constitutional studies at the Cato Institute, a libertarian research center in Washington.

Foreign entities, he said, have fewer rights under the U.S. Constitution, and there’s little chance that the accused will sway courts to force the U.S. government to share details.

“The way the modern courts interpret administration law, they give a wide berth to government agencies. … This seems to be more an issue of policy than constitutional,” Shapiro said.”

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

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

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

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

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

————————————————————–

International criminal questions, but want to be anonymous?

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U.S. eases Myanmar sanctions to boost NGO projects

April 18, 2012

Chicago Tribune on April 17, 2012 released the following:

“Reuters

WASHINGTON (Reuters) – The U.S. Treasury on Tuesday relaxed sanctions on Myanmar to permit financial transactions to support certain humanitarian and development projects in the country as it moves ahead with democratic reforms after decades of military rule.

The Treasury’s Office of Foreign Assets Control issued a general license authorizing financial transactions for a range of not-for-profit projects and programs in areas such as good governance, health, education and sport.

“We are taking this step today to support a broader range of not-for-profit activity in Burma by private U.S. organizations and individuals to promote increased cooperation between the Burmese and the American people,” a senior Treasury Department official said.

The Obama administration announced this month that it planned to gradually ease certain sanctions on Myanmar, steps that could eventually see bans lifted on U.S. companies investing in or offering financial services to the resource-rich Southeast Asian nation.

The move on sanctions follows a dramatic series of reforms in Myanmar, where Nobel Peace Prize laureate and pro-democracy icon Aung San Suu Kyi won a seat in a parliamentary by-election this month that yielded a landslide victory for her party.

“These (steps) were action for action in response to what we viewed as very positive parliamentary elections,” State Department spokesman Mark Toner told a news briefing, adding that additional measures would be forthcoming.

The Treasury’s announcement marked the first of a planned series of modest steps to unravel the complex web of U.S. sanctions that have contributed to the country’s isolation and driven it closer to its powerful neighbor, China.

The United States has said it will name an ambassador to Myanmar after an absence of two decades, set up an office of the U.S. Agency for International Development there and support a regular U.N. Development Program operation in the country.

Future steps to ease sanctions could eventually open the door to U.S. investment in Myanmar’s agriculture, tourism, telecommunications and banking sectors, U.S. officials say.

But U.S. officials say they want to see clear evidence of further reforms, including the release of all political prisoners, concrete steps toward national reconciliation, especially with ethnic groups that say they have long been oppressed by the central government, and an end to any military ties to North Korea.

Secretary of State Hillary Clinton, in a statement marking Myanmar’s New Year Water Festival on Tuesday, said the last year had seen the country embark “on a historic new path toward democracy and economic development.”

“We look forward to deepening cooperation on a wide range of issues that promote democratization and national reconciliation, from increasing access to education to expanding health care and encouraging a vibrant civil society,” she said.

Pro-democracy advocates have urged the United States to move cautiously, saying sanctions are an important tool to maintain pressure on Myanmar’s government to follow through on pledges of greater democratic openness.

“We need to carefully utilize the sanctions we have by gradually easing them. Major sanctions … should be the last ones to touch,” said Aung Din, president of the U.S. Campaign for Burma.”

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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 C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.


Clinton tells Congress 11 countries are reducing oil buys from Iran

March 21, 2012

CNN on March 21, 2012 released the following:

“By Adam Levine, CNN

WASHINGTON (CNN) — Eleven countries, including Japan and European nations, have significantly reduced their Iran oil purchases and should not be subject to new U.S. sanctions, U.S. Secretary of State Hillary Clinton told Congress Tuesday.

The countries are Japan, Belgium, the Czech Republic, France, Germany, Greece, Italy, the Netherlands, Poland, Spain, and the United Kingdom, according to a State Department statement.

“The actions taken by these countries were not easy. They had to rethink their energy needs at a critical time for the world economy and quickly begin to find alternatives to Iranian oil, which many had been reliant on for their energy needs,” said Clinton in the State Department statement.

“Only two months after the passage of the National Defense Authorization Act for 2012, we have made progress in shrinking Iran’s oil export markets, and isolating its Central Bank from the world financial system. The United States is leading an unprecedented international coalition of partners that has brought to bear significant pressure on the Iranian regime to change its course.”

There are 12 other countries purchasing oil from Iran that could face sanctions. A State Department official who briefed reporters on the announcement would not list the countries, but major importers of Iranian oil include China, India and South Korea.

Those countries could look at Japan as an example of how to ween off Iranian oil, said the State Department official. Japan has reduced its oil purchases from Iran by 15% to 22% in the last half of 2011, the official said.

The president needs to make a final decision by March 30 as to whether those other countries have or have not met the requirements to significantly reduce Iran oil purchases. If the president determines any countries have not, the countries’ banks will face sanctions starting at the end of June.”

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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 C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.