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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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 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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Executive Order: Blocking Property of Transnational Criminal Organizations

July 25, 2011

The White House Office of the Press Secretary on July 25, 2011 released the following:

“EXECUTIVE ORDER

BLOCKING PROPERTY OF TRANSNATIONAL CRIMINAL ORGANIZATIONS

By the authority vested in me as President by the Constitution and the laws of the United States of America, including the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), the National Emergencies Act (50 U.S.C. 1601 et seq.) (NEA), and section 301 of title 3, United States Code,

I, BARACK OBAMA, President of the United States of America, find that the activities of significant transnational criminal organizations, such as those listed in the Annex to this order, have reached such scope and gravity that they threaten the stability of international political and economic systems. Such organizations are becoming increasingly sophisticated and dangerous to the United States; they are increasingly entrenched in the operations of foreign governments and the international financial system, thereby weakening democratic institutions, degrading the rule of law, and undermining economic markets. These organizations facilitate and aggravate violent civil conflicts and increasingly facilitate the activities of other dangerous persons. I therefore determine that significant transnational criminal organizations constitute an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States, and hereby declare a national emergency to deal with that threat.

Accordingly, I hereby order:

Section 1. (a) All property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any United States person, including any overseas branch, of the following persons are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in:

      (i) the persons listed in the Annex to this order and
      (ii) any person determined by the Secretary of the Treasury, in consultation with the Attorney General and the Secretary of State:
        (A) to be a foreign person that constitutes a significant transnational criminal organization;
        (B) to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person whose property and interests in property are blocked pursuant to this order; or
        (C) to be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to this order.

(b) I hereby determine that the making of donations of the types of articles specified in section 203(b)(2) of IEEPA (50 U.S.C. 1702(b)(2)) by, to, or for the benefit of any person whose property and interests in property are blocked pursuant to this order would seriously impair my ability to deal with the
national emergency declared in this order, and I hereby prohibit such donations as provided by subsection (a) of this section.

(c) The prohibitions in subsection (a) of this section include, but are not limited to:

      (i) the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any person whose property and interests in property are blocked pursuant to this order; and
      (ii) the receipt of any contribution or provision of funds, goods, or services from any such person.

(d) The prohibitions in subsection (a) of this section apply except to the extent provided by statutes, or in regulations, orders, directives, or licenses that may be issued pursuant to this order, and notwithstanding any contract entered into or any license or permit granted prior to the effective date of this order.

Sec. 2. (a) Any transaction by a United States person or within the United States that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions set forth in this order is prohibited.

(b) Any conspiracy formed to violate any of the prohibitions set forth in this order is prohibited.

Sec. 3. For the purposes of this order:
(a) the term “person” means an individual or entity;

(b) the term “entity” means a partnership, association, trust, joint venture, corporation, group, subgroup, or other organization;

(c) the term “United States person” means any United States citizen, permanent resident alien, entity organized under the laws of the United States or any
jurisdiction within the United States (including foreign branches), or any person in the United States;

(d) the term “foreign person” means any citizen or national of a foreign state, or any entity organized under the laws of a foreign state or existing in a foreign state, including any such individual or entity who is also a United States person; and

(e) the term “significant transnational criminal organization” means a group of persons, such as those listed in the Annex to this order, that includes one or more foreign persons; that engages in an ongoing pattern of serious criminal activity involving the jurisdictions of at least two foreignstates; and that threatens the national security, foreign policy, or economy of the United States.

Sec. 4. For those persons whose property and interests in property are blocked pursuant to this order who might have a constitutional presence in the United States, I find that because of the ability to transfer funds or other assets instantaneously, prior notice to such persons of measures to be taken pursuant to this order would render these measures ineffectual. I therefore determine that for these measures to be effective in addressing the national emergency declared in this order, there need be no prior notice of a listing or determination made pursuant to section 1(a) of this order.

Sec. 5. The Secretary of the Treasury, in consultation with the Attorney General and the Secretary of State, is hereby authorized to take such actions, including the promulgation of rules and regulations, and to employ all powers granted to the President by IEEPA, as may be necessary to carry out the purposes of this order. The Secretary of the Treasury may redelegate any of these functions to other officers and agencies of the United States Government consistent with applicable law. All agencies of the United States Government are hereby directed to take all appropriate measures within their authority to carry out the provisions of this order.

Sec. 6. The Secretary of the Treasury, in consultation with the Attorney General and the Secretary of State, is hereby authorized to submit the recurring and final reports to the Congress on the national emergency declared in this order, consistent with section 401(c) of the NEA (50 U.S.C. 1641(c)) and section 204(c) of IEEPA (50 U.S.C. 1703(c)).

Sec. 7. The Secretary of the Treasury, in consultation with the Attorney General and the Secretary of State, is hereby authorized to determine that circumstances no longer warrant the blocking of the property and interests in property of a person listed in the Annex to this order, and to take necessary action to give effect to that determination.

Sec. 8. This order is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.

Sec. 9. This order is effective at 12:01 a.m. eastern daylight time on July 25, 2011.

BARACK OBAMA

THE WHITE HOUSE,
July 24, 2011.

ANNEX

Entities

  1. THE BROTHERS’ CIRCLE (f.k.a. FAMILY OF ELEVEN; f.k.a. THE TWENTY)
  2. CAMORRA
  3. YAKUZA (a.k.a. BORYOKUDAN; a.k.a. GOKUDO)
  4. LOS ZETAS​”

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 extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN List 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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New Executive Order Targets Alleged Significant Transnational Criminal Organizations

July 25, 2011

U.S. Department of the Treasury on July 25, 2011 released the following:

“President Obama has signed an Executive Order imposing sanctions against significant transnational criminal organizations (TCOs). The Order provides the United States with new tools to break the economic power of transnational organized crime and protect financial markets. It will assist the Administration’s efforts to disrupt, dismantle and defeat the TCOs that pose a significant threat to U.S. national security, foreign policy or the economy.

As a result of this Order, any property in the United States or in the possession or control of U.S. persons in which the significant TCOs listed in the Annex have an interest is blocked, and U.S. persons are prohibited from engaging in transactions with them.

The Order also authorizes the U.S. Department of the Treasury, in consultation with the Departments of Justice and State, to identify for sanctions any individual or entity determined to have materially assisted, sponsored or provided financial, material or technological support for any person whose property and interests in property are blocked pursuant to this Order.

In signing today’s Order, the President imposed sanctions on the following organizations listed in the Annex:

The Brothers’ Circle (Eurasia)
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 the Middle East, Africa and Latin America. Many Brothers’ Circle members share a common ideology based on the “thief-in-law” tradition, which seeks to spread their brand of criminal influence globally. The Brothers’ Circle serves as a coordinating body for several national level criminal networks, which includes mediating disputes between the individual criminal networks and directing global criminal activity.

The Camorra (Italy)
Considered the largest Italian organized crime group, the Camorra is a loose collection of allied and competing local clans in the province of Naples and the Campania region of Italy. The Camorra operates internationally and is involved in serious criminal activity such as counterfeiting and narcotics trafficking.

The Camorra may earn more than 10 percent of its roughly $25 billion annual profit through the sale of counterfeit and pirated goods – such as luxury clothing, power tools, CDs, DVDs, and software – in European and U.S. markets. The Camorra’s counterfeiting and piracy activities undermine U.S. sales of genuine products and deny U.S. copyright holders of profits. The International Intellectual Property Alliance (IIPA), a private sector coalition of trade associations, estimates that copyright piracy causes trade losses with Italy of more than $1 billion every year.

The Yakuza (Japan)
The Yakuza comprises the major Japanese organized crime syndicates, sometimes referred to as “families,” and had more than 80,000 members as of 2008. The Yakuza derives most of its profits from the drug trade, particularly methamphetamine, the most widely abused drug in Japan. The Yakuza also profits from other serious criminal activities, including weapons trafficking and nearly all aspects of sexual exploitation: sex tourism, prostitution, human trafficking, “mail order” marriages, pornography, and the exploitation of women and children, with the help of local crime syndicates in East Asia. The Yakuza is also heavily involved in white-collar crime, often using front companies to hide illicit proceeds within legitimate industries, including construction, real estate and finance.

In addition to its networks in Japan, the Yakuza acts globally. It has relationships with criminal affiliates in Asia, Europe and the Americas. In the United States, the Yakuza has been involved primarily in drug trafficking and money laundering.

Los Zetas (Mexico)
Formerly the armed wing of the Gulf Cartel, Los Zetas is an extremely violent transnational criminal organization based primarily in Mexico. The organization is estimated to have thousands of members in Mexico, Central America and the United States. Los Zetas facilitates drug trafficking into the United States and has relationships with U.S.-based gangs. Los Zetas is specifically responsible for the safe passage of large quantities of illegal narcotics, including cocaine, methamphetamine, heroin and marijuana moving through Mexico and eventually into the United States. In addition to drug trafficking, Los Zetas is involved in extortion, money laundering, intellectual property theft and human smuggling. Los Zetas and Gulf Cartel members together are named in multiple indictments in Federal District courts for violating U.S. narcotics laws. These indictments allege that Los Zetas has carried out numerous acts of violence, including murders, kidnappings and tortures.

Los Zetas members are responsible for mass murders in Mexico and Guatemala, and have demonstrated their capacity and willingness to intimidate and brazenly kill law enforcement and other government personnel. In February 2011, Los Zetas members ambushed and killed Immigration and Customs Enforcement (ICE) Special Agent Jaime Zapata and seriously wounded ICE Agent Victor Avila. In April 2011, Mexico’s Office of the Attorney General announced the arrest of Los Zetas cell leaders connected to the discovery of nearly 200 bodies dumped in mass graves in San Fernando, Tamaulipas, Mexico. The victims were kidnapped from passenger buses traveling toward the U.S.-Mexico border. In May 2011, Los Zetas members stormed a ranch in northern Guatemala and killed 27 people and later killed the Guatemalan prosecutor involved in the investigation of the murders.

The President identified Los Zetas as a significant foreign narcotics trafficker under the Foreign Narcotics Kingpin Designation Act in 2009. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has since designated four principal Los Zetas and Gulf Cartel leaders and 54 Mexican principal lieutenants and enforcers for Los Zetas and the Gulf Cartel pursuant to the Kingpin Act.​”

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 extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN List 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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Transnational Criminal Organizations [TCO] Added on OFAC’s SDN List on July 25, 2011

July 25, 2011

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

The following Transnational Criminal Organizations [TCO] entries have been added to 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]

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]

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]

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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 List 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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