OFAC Licensing Policy statement regarding exports of commercial aircraft, parts and services to Iran

Filed under: Iranian Sanctions, Licenses, OFAC Updates, Sanctions Regulations

C. Sanctions Related to Iran’s Energy and Petrochemical Sectors

Commitment:

Section 4.3 of Annex II and section 17.1 of Annex V of the JCPOA provide for the lifting, on
Implementation Day, of secondary sanctions that apply to non-U.S. persons who engage in
certain activities related to the energy sector of Iran. In particular, beginning on Implementation
Day, the following activities by non-U.S. persons are no longer sanctionable:

Investment, including participation in joint ventures, goods, services, information,
technology and technical expertise and support for Iran’s oil, gas, and petrochemical
sectors (see section 4.3.2 of Annex II of the JCPOA);

The purchase, acquisition, sale, transportation, or marketing of petroleum, petrochemical
products and natural gas from Iran (see section 4.3.3 of Annex II of the JCPOA);

The export, sale, or provision of refined petroleum products and petrochemical products
to Iran (see section 4.3.4 of Annex II of the JCPOA);

Transactions with Iran’s energy sector, including with NIOC, NICO, and NITC (see
section 4.3.5 of Annex II of the JCPOA); and

The provision of associated services for each of the categories above (see section 4.3.6 of
Annex II of the JCPOA).

In addition, the United States has ceased efforts to reduce Iran’s crude oil sales, including
limitations on the quantities of Iranian crude oil sold and the nations that can purchase Iranian
crude oil, and has lifted sanctions on the provision of associated services (see sections 4.3.1 and
4.3.6 of Annex II of the JCPOA).34

Implementation:

To effectuate the lifting of these sanctions on Implementation Day, the USG, in addition to
removing certain individuals and entities from the SDN List, FSE List, and NS-ISA List as
described in section III below, took the following steps:

1. Correspondent or Payable-Through Account Sanctions:

a. Waived the imposition of correspondent or payable-through account sanctions
under: section 1245(d)(1) of NDAA 2012 (for significant financial transactions by
FFIs with the CBI)35; section 1244(d)(2) of IFCA (for significant financial
transactions by FFIs for the sale, supply, or transfer to or from Iran of significant
goods or services used in connection with the energy, shipping, or shipbuilding
sectors of Iran, including NIOC, NITC, and IRISL); section 1244(h)(2) of IFCA
(for financial transactions by FFIs for the sale, supply, or transfer to or from Iran of natural gas)36; section 1245(c) of IFCA (for significant financial transactions
by FFIs for the sale, supply, or transfer to or from Iran of precious metals or
specified materials (graphite, raw or semi-finished metals such as aluminum and
steel, coal, and software for integrating industrial processes) that are within the
scope of the waivers under section 1245(a)(1) of IFCA, as described in section VI
below); and section 1247(a) of IFCA.37

b. Revoked: E.O. 13622, including the correspondent or payable-through account
sanctions under section 1(a), as amended by section 16 of E.O. 13645 (for FFIs
that conduct or facilitate transactions: with NIOC or NICO; for the purchase,
acquisition, sale, transport, or marketing of petroleum or petroleum products from
Iran; or for the purchase, acquisition, sale, transport, or marketing of
petrochemical products from Iran); and E.O. 13645, including the correspondent
or payable-through account sanctions under section 3(a)(i) (for significant
transactions by FFIs on behalf of any Iranian person on the SDN List or any other
person included on the SDN List whose property and interests in property are
blocked pursuant to subsection 2(a)(i) of E.O. 13645 or E.O. 13599).38

c. Committed to refrain from imposing sanctions under sections 561.203(a) of the
IFSR for transactions by FFIs with the CBI that are consistent with the waiver of
section 1245(d)(1) of NDAA 2012.

2. Blocking Sanctions:

a. Waived the imposition of blocking sanctions under section 1244(c)(1) of IFCA39 (with respect to non-U.S. persons who knowingly provide significant financial, material, technological, or other support to, or goods or services in support of any activity or transaction on behalf of or for the benefit of a person determined to be part of the energy, shipping, or shipbuilding sectors of Iran or to operate a port in Iran, or Iranian individuals or entities set forth in Attachment 3 to Annex II of the JCPOA).40

b. Revoked: E.O. 13622, including the blocking sanctions under section 5(a) (with respect to persons who have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, NIOC, NICO, or the CBI, or the purchase or acquisition of U.S. bank notes or precious metals by the Government of Iran); and E.O. 13645, including the blocking sanctions under section 2(a)(i) (with respect to persons who have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any Iranian person included on the SDN List or any other person included on the SDN List whose property and interests in
property are blocked pursuant to subsection 2(a)(i) of E.O. 13645 or E.O.
13599).41

3. Menu-based Sanctions:

a. Waived the imposition of menu-based sanctions under:

i. Section 5(a) of ISA (with respect to non-U.S. persons who: make
investments above specified thresholds that could directly and
significantly contribute to the maintenance or enhancement of Iran’s
ability to develop petroleum resources; knowingly sell, lease, or provide to
Iran goods, services, technology, information, or support that could
directly and significantly facilitate the maintenance or enhancement of
Iran’s domestic production of refined petroleum products; sell or provide
to Iran refined petroleum products or sell, lease, or provide to Iran goods,
services, technology, information, or support that could directly and
significantly contribute to the enhancement of Iran’s ability to import
refined petroleum products; knowingly participate in certain joint ventures
for the development of petroleum resources outside of Iran; knowingly
sell, lease, or provide to Iran goods, services, technology, information, or
support that could directly and significantly contribute to the maintenance
or enhancement of Iran’s ability to develop petroleum resources located in
Iran or domestic production of refined petrochemical products; knowingly
sell, lease, or provide to Iran goods, services, technology, or support that
could directly and significantly contribute to the maintenance or expansion
of Iran’s domestic production of petrochemical products; own, operate, or
control, or insure a vessel used to transport crude oil from Iran to another
country; or own, operate, or control a vessel used in a manner that
conceals the Iranian origin of crude oil or refined petroleum products
transported on the vessel);

ii.Section 212(a) of the TRA (with respect to non-U.S. persons who
knowingly provide underwriting services or insurance or reinsurance for
NIOC, NITC, or a successor entity to either company, in cases where the
transactions are for activities described in sections 4.2, 4.3, and 4.4 of
Annex II of the JCPOA);

iii. Section 1244(d)(1) of IFCA (with respect to non-U.S. persons who
knowingly sell, supply, or transfer to or from Iran significant goods or
services used in connection with the energy, shipping, or shipbuilding
sectors of Iran, including NIOC, NITC, and IRISL);

iv. Section 1245(a)(1) of IFCA (with respect to non-U.S. persons who sell,
supply, or transfer to or from Iran precious metals or specified materials
(graphite, raw or semi-finished metals such as aluminum and steel, coal,
and software for integrating industrial processes), subject to certain
limitations as described in section VI below); and

v. Section 1246(a) of IFCA42 (for non-U.S. persons who provide
underwriting services, insurance, or reinsurance in connection with
activities involving Iran that are described in sections 17.1 to 17.2 and
17.5 of Annex V of the JCPOA, or to or for any individual or entity whose
property and interests in property are blocked solely pursuant to E.O.
13599).

b. Revoked: E.O. 13574, including section 1 (providing implementation authority for
certain menu-based sanctions under ISA); E.O. 13590, including section 1
(providing for menu-based sanctions with respect to persons who knowingly sell,
lease, or provide to Iran goods, services, technology, or support that could directly
and significantly contribute to the maintenance or expansion of Iran’s domestic
production of petrochemical products); E.O. 13622, including section 2(a)(i)-(iii),
as amended by section 16 of E.O. 13645 (for persons engaging in significant
transactions for the purchase, acquisition, sale, transport, or marketing of
petroleum, petroleum products, and petrochemical products from Iran and
successor entities of such non-U.S. persons); and section 5 of E.O. 13628
(providing for menu-based sanctions with respect to persons who knowingly,
between July 1, 2010, and August 10, 2012: sold, leased, or provided to Iran
goods, services, technology, information, or support that could directly and
significantly facilitate the maintenance or expansion of Iran’s domestic production
of refined petroleum products; sold or provided to Iran refined petroleum
products; or sold, leased, or provided to Iran goods, services, technology,
information, or support that could directly and significantly contribute to the
enhancement of Iran’s ability to import refined petroleum products).

See section III for an overview of the sanctions list removals that occurred on Implementation
Day and section VI for an overview of the waiver determinations and findings issued in
connection with the JCPOA.

Effects of the lifting of sanctions on the energy and petrochemical sectors:

As a result of the lifting of sanctions specified in sections 4.3.1 to 4.3.6 of Annex II and section
17.1 of Annex V of the JCPOA and described in this section, beginning on Implementation Day
such sanctions, including sanctions on associated services, do not apply to non-U.S. persons
who: (i) are part of the energy sector of Iran; (ii) purchase, acquire, sell, transport, or market
petroleum, petroleum products (including refined petroleum products), petrochemical products,
or natural gas (including liquefied natural gas) to or from Iran; (iii) provide to Iran support, investment (including through joint ventures), goods, services (including financial services), and
technology that can be used in connection with Iran’s energy sector, the development of its
petroleum resources, and its domestic production of refined petroleum products and
petrochemical products; or (iv) engage in activities with Iran’s energy sector, including NIOC,
NITC, and NICO.\

For additional information on the energy and petrochemical sector-related sanctions lifting
discussed in this subsection, please see section B of the JCPOA FAQs.

Filed under: Guidance, Iranian Sanctions, Joint Comprehensive Plan of Action (JCPOA) Updates, OFAC Updates, Sanctions Regulations

Importation of Certain Foodstuffs and Carpets

To implement the USG commitment set out in section 5.1.3 of Annex II and section 17.5of Annex V of the JCPOA to license the importation into the United States of Iranian-origincarpets and foodstuffs, including pistachios and caviar, OFAC is adding § 560.534 to the ITSR toauthorize by general license the importation into the United States of, and dealings in, certainIranian-origin foodstuffs and carpets from Iran or a third country. OFAC’s publication of thisgeneral license as an amendment to the ITSR fulfills the requirements of section 103(d)(2)(A) ofthe Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, as amended,(Pub. L. 111–195) (22 U.S.C. 8501-8551) (CISADA). In addition, to fulfill the requirements ofsection 103(d)(2)(B) of CISADA, the Secretary of State is submitting to the appropriatecongressional committees a certification in writing that it is in the national interest of the UnitedStates to provide an exception to the prohibition on the importation of Iranian-origin goods to theextent required to implement the sanctions commitment described in section 5.1.3 of Annex II ofthe JCPOA and a report describing the reasons for this exception.

Section 560.534(a) authorizes the importation into the United States of Iranian-originfoodstuffs intended for human consumption that are classified under chapters 2–23 of theHarmonized Tariff Schedule of the United States (HTS). Items that are classified in chapters 2-23 of the HTS that are not foodstuffs intended for human consumption are not authorized forimportation into the United States by this section. This section also authorizes the importationinto the United States of Iranian-origin carpets and other textile floor coverings and carpets usedas wall hangings that are classified under chapter 57 or heading 9706.00.0060 of the HTS. Items that are classified under heading 9706.00.0060 (“Antiques of an age exceeding one hundred
years/Other”) that are not carpets and other textile wall coverings or carpets used as wall
hangings are not authorized for importation into the United States by this section.

Section 560.534(b) authorizes U.S. persons, wherever located, to engage in transactions
or dealings in or related to such Iranian-origin foodstuffs and carpets, provided that such
transactions or dealings do not involve or relate to goods, technology, or services for exportation,
reexportation, sale, or supply, directly or indirectly, to Iran, the Government of Iran, an Iranian
financial institution, or any other person whose property and interests in property are blocked
pursuant to § 560.211 of the ITSR, other than services described in § 560.405 (“Transactions
ordinarily incident to a licensed transaction authorized”) and transfers of funds described in
§ 560.5

§ 560.516 (“Transfers of funds involving Iran”). Section 560.534(c) clarifies that § 560.534(a)-
(b) does not authorize the importation into the United States of goods that are under seizure or
detention by the Department of Homeland Security, or of goods for which forfeiture proceedings
have commenced or of goods that have been forfeited to the U.S. Government. Section
560.534(d) clarifies that nothing in § 560.534 authorizes the debiting or crediting of Iranian
accounts, as defined in § 560.320.

Transactions ordinarily incident to the transactions authorized in § 560.534 and necessary
to give effect thereto also are authorized as set forth in § 560.405. OFAC is amending § 560.405
by inserting new paragraph (f), which clarifies that the scope of authorized incidental transactions does not include letter of credit services relating to transactions authorized in § 560.534. Those letter of credit services that are authorized are set forth separately in paragraphs (a) and (b) of § 560.535, which OFAC is also adding to the ITSR. Please see

§§ 560.405(b) and 560.516 regarding transfers of funds in connection with licensed activities.
Brokering services relating to transactions authorized by this final rule also are authorized. See
§ 560.535(c).

Link:

Final Rule document

Filed under: Guidance, Iranian Sanctions, Licenses, OFAC Updates, Sanctions Regulations

D. Sanctions Related to Iran’s Shipping and Shipbuilding Sectors and Port
Operators

Commitment:

Section 4.4 of Annex II and section 17.1 of Annex V of the JCPOA provide for the lifting, on
Implementation Day, of secondary sanctions that apply to non-U.S. persons with respect to Iran’s
shipping and shipbuilding sectors and port operators. In particular, beginning on Implementation
Day, the following activities by non-U.S. persons are no longer sanctionable:

Transactions with Iran’s shipping and shipbuilding sectors and port operators, including
IRISL, South Shipping Line, and NITC, and the port operator(s) of Bandar Abbas43 (see
section 4.4.1 of Annex II of the JCPOA); and

The provision of associated services for the categories above (see section 4.4.2 of Annex
II of the JCPOA).

Implementation:

To effectuate the lifting of these sanctions on Implementation Day, the USG, in addition to
removing certain individuals and entities from the SDN List, FSE List, and NS-ISA List as
described in section III below, took the following steps:

1. Correspondent or Payable-Through Account Sanctions:

a. Waived the imposition of correspondent or payable-through account sanctions
under: section 1245(d)(1) of NDAA 2012 (for significant financial transactions by
FFIs with the CBI)44; section 1244(d)(2) of IFCA (for significant financial
transactions by FFIs for the sale, supply, or transfer to or from Iran of significant
goods or services used in connection with the energy, shipping, or shipbuilding
sectors of Iran, including NIOC, NITC, and IRISL); section 1245(c) of IFCA (for
significant financial transactions by FFIs for the sale, supply, or transfer to or
from Iran of precious metals or specified materials (graphite, raw or semi-finished metals such as aluminum and steel, coal, and software for integrating industrial
processes) that are within the scope of the waivers under section 1245(a)(1) of
IFCA, as described in section VI below); and section 1247(a) of IFCA.45

b. Revoked E.O. 13645, including the correspondent or payable-through account
sanctions under subsection 3(a)(i) (for significant transactions by FFIs on behalf
of any Iranian person on the SDN List or any other person included on the SDN
List whose property and interests in property are blocked pursuant to subsection
2(a)(i) of E.O. 13645 or E.O. 13599).46

c. Committed to refrain from imposing sanctions under section 561.203(a) of the
IFSR for transactions by FFIs with the CBI that are consistent with the waiver of
section 1245(d)(1) of NDAA 2012.

Blocking Sanctions:

a. Waived the imposition of blocking sanctions under section 1244(c)(1) of IFCA47
(with respect to non-U.S. persons who knowingly provide significant financial,
material, technological, or other support to, or goods or services in support of any
activity or transaction on behalf of or for the benefit of a person determined to be
part of the energy, shipping, or shipbuilding sectors of Iran or to operate a port in
Iran, or Iranian individuals or entities set forth in Attachment 3 to Annex II of the
JCPOA).48

b. Revoked: E.O. 13622, including the blocking sanctions under section 5(a) (with
respect to persons who have materially assisted, sponsored, or provided financial,
material, or technological support for, or goods or services in support of, NIOC,
NICO, or the CBI, or the purchase or acquisition of U.S. bank notes or precious
metals by the Government of Iran); and E.O. 13645, including the blocking
sanctions under subsection 2(a)(i) (with respect to persons who have materially
assisted, sponsored, or provided financial, material, or technological support for,
or goods or services to or in support of, any Iranian person included on the SDN
List or any other person included on the SDN List whose property and interests in
property are blocked pursuant to subsection 2(a)(i) of E.O. 13645 or E.O.
13599).49

Menu-based Sanctions:

a. Waived the imposition of menu-based sanctions under: section 212(a) of the TRA
(with respect to non-U.S. persons who knowingly provide underwriting services or insurance or reinsurance for NIOC, NITC, or a successor entity to either
company, in cases where the transactions are for activities described in section 4.4
of Annex II of the JCPOA); section 1244(d)(1) of IFCA (with respect to non-U.S.
persons who knowingly sell, supply, or transfer to or from Iran significant goods
or services used in connection with the energy, shipping, or shipbuilding sectors
of Iran, including NIOC, NITC, and IRISL); sections 1245(a)(1)(B),
1245(a)(1)(C)(i)(I)-(II) and 1245(a)(1)(C)(ii)(I)-(II) of IFCA (with respect to non-
U.S. persons who sell, supply, or transfer to or from Iran specified materials
(graphite, raw or semi-finished metals such as aluminum and steel, coal, and
software for integrating industrial processes), subject to certain limitations as
described in section VI below); and section 1246(a) of IFCA50 (for non-U.S.
persons who provide underwriting services, insurance, or reinsurance in
connection with activities involving Iran that are described in sections 17.1 to
17.2 and 17.5 of Annex V of the JCPOA, or to or for any individual or entity
whose property and interests in property are blocked solely pursuant to E.O.
13599).

See section III for an overview of the sanctions list removals that occurred on Implementation
Day and section VI for an overview of the waiver determinations and findings issued in
connection with the JCPOA.

Effects of the lifting of the sanctions related to Iran’s shipping and shipbuilding sectors and
port operators:

As a result of the lifting of sanctions specified in sections 4.4.1 to 4.4.2 of Annex II and 17.1 of
Annex V of the JCPOA and described in this section, beginning on Implementation Day such
sanctions, including sanctions on associated services, do not apply to non-U.S. persons who are
part of the shipping or shipbuilding sectors of Iran or who: own, operate, control, or insure a
vessel used to transport crude oil, petroleum products (including refined petroleum products),
petrochemical products, or natural gas (including liquefied natural gas) to or from Iran; operate a
port in Iran, engage in activities with, or provide financial services and other goods and services
used in connection with, the shipping and shipbuilding sectors of Iran or a port operator in Iran
(including the port operator(s) of Bandar Abbas51), including port services, such as bunkering
and inspection, classification, and financing, and the sale, leasing, and provision of vessels to
Iran, including to IRISL, NITC, and South Shipping Line or their affiliates.

For additional information on the sanctions lifting related to Iran’s shipping and shipping
sectors and port operators discussed in this subsection, please see section E of the JCPOA FAQs.

Filed under: Guidance, Iranian Sanctions, Joint Comprehensive Plan of Action (JCPOA) Updates, OFAC Updates, Sanctions Regulations

On Wednesday, OFAC made a number of changes to a variety of programs. First, they revoked Zimbabwe General License 1, which authorized transactions with 2 Zimbabwean banks. Why? Because they removed them from the SDN List:

AGRICULTURAL DEVELOPMENT BANK OF ZIMBABWE (a.k.a. AGRIBANK; a.k.a. AGRICULTURAL BANK OF ZIMBABWE), 15th Floor, Hurudza House, 14-16 Nelson Mandela Avenue, Harare, Zimbabwe; Box 369, Harare, Zimbabwe; Phone No. 263-4-774426; Fax No. 263-4-774556 [ZIMBABWE].

AGRIBANK (a.k.a. AGRICULTURAL BANK OF ZIMBABWE; a.k.a. AGRICULTURAL DEVELOPMENT BANK OF ZIMBABWE), 15th Floor, Hurudza House, 14-16 Nelson Mandela Avenue, Harare, Zimbabwe; Box 369, Harare, Zimbabwe; Phone No. 263-4-774426; Fax No. 263-4-774556 [ZIMBABWE].

AGRICULTURAL BANK OF ZIMBABWE (a.k.a. AGRIBANK; a.k.a. AGRICULTURAL DEVELOPMENT BANK OF ZIMBABWE), 15th Floor, Hurudza House, 14-16 Nelson Mandela Avenue, Harare, Zimbabwe; Box 369, Harare, Zimbabwe; Phone No. 263-4-774426; Fax No. 263-4-774556 [ZIMBABWE].

INFRASTRUCTURE DEVELOPMENT BANK OF ZIMBABWE (a.k.a. ZIMBABWE DEVELOPMENT BANK), ZDB House, 99 Rotten Row, Harare, Mashonaland East, Zimbabwe; P.O. Box 1720, Harare, Zimbabwe; Phone No. 263-4-7501718; Fax No. 263-4-7744225 [ZIMBABWE].

ZIMBABWE DEVELOPMENT BANK (a.k.a. INFRASTRUCTURE DEVELOPMENT BANK OF ZIMBABWE), ZDB House, 99 Rotten Row, Harare, Mashonaland East, Zimbabwe; P.O. Box 1720, Harare, Zimbabwe; Phone No. 263-4-7501718; Fax No. 263-4-7744225[ZIMBABWE].

Additionally, OFAC removed the following persons from Zimbabwean sanctions:

MIDZI, Amos Bernard Muvenga; DOB 04 Jul 1952; Minister of Mines and Mining Development (individual) [ZIMBABWE].

NDLOVU, Sikhanyiso Duke; DOB 04 May 1937; Passport ZD001355 (Zimbabwe); Deputy Minister of Higher and Tertiary Education (individual) [ZIMBABWE].

SAKUPWANYA, Stanley; DOB circa 1945; Deputy Secretary for Disabled and Disadvantaged (individual) [ZIMBABWE].

NDLOVU MOTORWAYS, c/o Sam Nujoma Street/Livingston Avenue, Harare, Zimbabwe [ZIMBABWE].

NDLOVU, Rose Jaele; DOB 27 Sep 1939; Passport AD000813 (Zimbabwe); Spouse of Sikhanyiso Ndlovu (individual) [ZIMBABWE].

TAVEESIN, Nalinee (a.k.a. TAVEESIN, Nalinee Joy; a.k.a. TAWEESIN, NALINEE), 14th Floor of Modern Tower, Tower 87/110 Sukhumvit 63, Wattana, Bangkok 10110, Thailand; 33 Soi Soonvijai 4, Rama IX Road, Soi 26, Success Tower, Huai Khwang, Bang Kapi, Bangkok 10320, Thailand; 19-8 Soi Passana 3, Sukhumvit Road, Pakanong Nua, Wattana, Bangkok 10110, Thailand; 33 Soi Soonwichai 4 Bangkapi, Huaykhwang, Bangkok 10310, Thailand; DOB 12 Feb 1960; nationality Thailand; citizen Thailand; Passport Z066420 (Thailand); Managing Director (individual) [ZIMBABWE].

TAVEESIN, Nalinee Joy (a.k.a. TAVEESIN, Nalinee; a.k.a. TAWEESIN, NALINEE), 14th Floor of Modern Tower, Tower 87/110 Sukhumvit 63, Wattana, Bangkok 10110, Thailand; 33 Soi Soonvijai 4, Rama IX Road, Soi 26, Success Tower, Huai Khwang, Bang Kapi, Bangkok 10320, Thailand; 19-8 Soi Passana 3, Sukhumvit Road, Pakanong Nua, Wattana, Bangkok 10110, Thailand; 33 Soi Soonwichai 4 Bangkapi, Huaykhwang, Bangkok 10310, Thailand; DOB 12 Feb 1960; nationality Thailand; citizen Thailand; Passport Z066420 (Thailand); Managing Director (individual) [ZIMBABWE].

TAWEESIN, NALINEE (a.k.a. TAVEESIN, Nalinee; a.k.a. TAVEESIN, Nalinee Joy), 14th Floor of Modern Tower, Tower 87/110 Sukhumvit 63, Wattana, Bangkok 10110, Thailand; 33 Soi Soonvijai 4, Rama IX Road, Soi 26, Success Tower, Huai Khwang, Bang Kapi, Bangkok 10320, Thailand; 19-8 Soi Passana 3, Sukhumvit Road, Pakanong Nua, Wattana, Bangkok 10110, Thailand; 33 Soi Soonwichai 4 Bangkapi, Huaykhwang, Bangkok 10310, Thailand; DOB 12 Feb 1960; nationality Thailand; citizen Thailand; Passport Z066420 (Thailand); Managing Director (individual) [ZIMBABWE].

And the following persons from the anti-narcotics sanctions:

MATTHEWS, Glenroy Vingrove (a.k.a. MATHEW, Glenroy; a.k.a. MATTHEW, Glenroy Wingrove; a.k.a. MATTHEWS, Glen Roy), Frigate Bay, Saint Kitts and Nevis; DOB 26 Jul 1958; POB St Kitts and Nevis; Passport 047815 (Saint Kitts and Nevis) (individual) [SDNTK].

MATHEW, Glenroy (a.k.a. MATTHEW, Glenroy Wingrove; a.k.a. MATTHEWS, Glen Roy; a.k.a. MATTHEWS, Glenroy Vingrove), Frigate Bay, Saint Kitts and Nevis; DOB 26 Jul 1958; POB St Kitts and Nevis; Passport 047815 (Saint Kitts and Nevis) (individual) [SDNTK].

MATTHEW, Glenroy Wingrove (a.k.a. MATHEW, Glenroy; a.k.a. MATTHEWS, Glen Roy; a.k.a. MATTHEWS, Glenroy Vingrove), Frigate Bay, Saint Kitts and Nevis; DOB 26 Jul 1958; POB St Kitts and Nevis; Passport 047815 (Saint Kitts and Nevis) (individual) [SDNTK].

MATTHEWS, Glen Roy (a.k.a. MATHEW, Glenroy; a.k.a. MATTHEW, Glenroy Wingrove; a.k.a. MATTHEWS, Glenroy Vingrove), Frigate Bay, Saint Kitts and Nevis; DOB 26 Jul 1958; POB St Kitts and Nevis; Passport 047815 (Saint Kitts and Nevis) (individual) [SDNTK].

MIRCHI, Iqbal (a.k.a. MAMEN, Mohamed Iqbal; a.k.a. MEMON, Iqbal Mohammed; a.k.a. MERCHANT, Iqbal); DOB 25 Apr 1950; alt. DOB 12 Aug 1959; alt. DOB 13 Feb 1959; POB Bombay, India; Passport C-602033 (India); alt. Passport G-679302 (United Arab Emirates); alt. Passport H-825326 (United Arab Emirates) (individual) [SDNTK].

MAMEN, Mohamed Iqbal (a.k.a. MEMON, Iqbal Mohammed; a.k.a. MERCHANT, Iqbal; a.k.a. MIRCHI, Iqbal); DOB 25 Apr 1950; alt. DOB 12 Aug 1959; alt. DOB 13 Feb 1959; POB Bombay, India; Passport C-602033 (India); alt. Passport G-679302 (United Arab Emirates); alt. Passport H-825326 (United Arab Emirates) (individual) [SDNTK].

MEMON, Iqbal Mohammed (a.k.a. MAMEN, Mohamed Iqbal; a.k.a. MERCHANT, Iqbal; a.k.a. MIRCHI, Iqbal); DOB 25 Apr 1950; alt. DOB 12 Aug 1959; alt. DOB 13 Feb 1959; POB Bombay, India; Passport C-602033 (India); alt. Passport G-679302 (United Arab Emirates); alt. Passport H-825326 (United Arab Emirates) (individual) [SDNTK].

MERCHANT, Iqbal (a.k.a. MAMEN, Mohamed Iqbal; a.k.a. MEMON, Iqbal Mohammed; a.k.a. MIRCHI, Iqbal); DOB 25 Apr 1950; alt. DOB 12 Aug 1959; alt. DOB 13 Feb 1959; POB Bombay, India; Passport C-602033 (India); alt. Passport G-679302 (United Arab Emirates); alt. Passport H-825326 (United Arab Emirates) (individual) [SDNTK].

BORBOA ZAZUETA, Zynthia (a.k.a. BORBOA DE ZAMBADA, Zynthya; a.k.a. BORBOA ZAZUETA, Cinthia), c/o MULTISERVICIOS JEVIZ S.A. DE C.V., Culiacan, Sinaloa, Mexico; Calle Miguel Hidalgo PTE 348, Centro Culiacan, Sinaloa, Mexico; Manuel Bonilla 1166, Guadalupe, Culiacan, Sinaloa, Mexico; Lago Maracaibo 3121, Lago Azul y Ave Lago Azul, Lomas de Boulevard, Culiacan, Sinaloa, Mexico; DOB 30 Jan 1975; POB Sinaloa, Mexico; nationality Mexico; citizen Mexico; Passport 04040046465 (Mexico); R.F.C. BOZZ-750130-LK4 (Mexico); C.U.R.P. BOZC750130MSLRZN09 (Mexico) (individual) [SDNTK].

BORBOA ZAZUETA, Cinthia (a.k.a. BORBOA DE ZAMBADA, Zynthya; a.k.a. BORBOA ZAZUETA, Zynthia), c/o MULTISERVICIOS JEVIZ S.A. DE C.V., Culiacan, Sinaloa, Mexico; Calle Miguel Hidalgo PTE 348, Centro Culiacan, Sinaloa, Mexico; Manuel Bonilla 1166, Guadalupe, Culiacan, Sinaloa, Mexico; Lago Maracaibo 3121, Lago Azul y Ave Lago Azul, Lomas de Boulevard, Culiacan, Sinaloa, Mexico; DOB 30 Jan 1975; POB Sinaloa, Mexico; nationality Mexico; citizen Mexico; Passport 04040046465 (Mexico); R.F.C. BOZZ-750130-LK4 (Mexico); C.U.R.P. BOZC750130MSLRZN09 (Mexico) (individual) [SDNTK].

BORBOA DE ZAMBADA, Zynthya (a.k.a. BORBOA ZAZUETA, Cinthia; a.k.a. BORBOA ZAZUETA, Zynthia), c/o MULTISERVICIOS JEVIZ S.A. DE C.V., Culiacan, Sinaloa, Mexico; Calle Miguel Hidalgo PTE 348, Centro Culiacan, Sinaloa, Mexico; Manuel Bonilla 1166, Guadalupe, Culiacan, Sinaloa, Mexico; Lago Maracaibo 3121, Lago Azul y Ave Lago Azul, Lomas de Boulevard, Culiacan, Sinaloa, Mexico; DOB 30 Jan 1975; POB Sinaloa, Mexico; nationality Mexico; citizen Mexico; Passport 04040046465 (Mexico); R.F.C. BOZZ-750130-LK4 (Mexico); C.U.R.P. BOZC750130MSLRZN09 (Mexico) (individual) [SDNTK].

ZARKA DE MEXICO S.A. DE C.V., Miguel Hidalgo No. 348 Pte., Colonia Centro, Donato Guerra y Carrasco, Culiacan, Sinaloa, Mexico; R.F.C. ZME-040520-VD7 (Mexico); Folio Mercantil No. 73894-1 (Mexico) [SDNTK].

ZARKA DE OCCIDENTE S.A. DE C.V., Calle Jose Diego Valadez Rios No. 1676, Colonia Proyecto Urbano Tres Rios, Culiacan, Sinaloa, Mexico; Folio Mercantil No. 72191-1 (Mexico) [SDNTK].

CHAN INZUNA, Araceli; DOB 08 Feb 1985; nationality Mexico; Passport 03040074084(Mexico) (individual) [SDNTK].

MEZA FLORES, Flor Angely; DOB 20 Sep 1989; POB Guasave, Sinaloa, Mexico; nationality Mexico; Passport 040068790 (Mexico) (individual) [SDNTK].

ADIB MADERO, Michel; DOB 21 Feb 1977; POB Jalisco, Mexico; Cedula No. 3348806 (Mexico); R.F.C. AIMM770221CJ7 (Mexico); C.U.R.P. AIMM770221HJCDDC08 (Mexico) (individual) [SDNTK] (Linked To: RESTAURANT BAR LOS ANDARIEGOS, S.A. DE C.V.; Linked To: BOCADOS DE AUTOR, S.A. DE C.V.).

Also, the following 2 listings made under the anti-terror sanctions:

AL-KAWARI, ‘Abd al-Latif Bin ‘Abdallah Salih Muhammad (a.k.a. AL-KAWARI, ‘Abd-al-Latif ‘Abdallah; a.k.a. AL-KAWARI, ‘Abd-al-Latif ‘Abdallah Salih; a.k.a. AL-KAWWARI, ‘Abd-al-Latif ‘Abdallah; a.k.a. AL-KUWARI, ‘Abd-al-Latif ‘Abdallah Salih; a.k.a. “Abu Ali al-Kawari”), al-Laqtah, Qatar; DOB 28 Sep 1973; nationality Qatar; Passport 01020802 (Qatar); alt. Passport 00754833 (Qatar) issued 20 May 2007; alt. Passport 00490327 (Qatar) issued 28 Jul 2001; National ID No. 27363400684 (Qatar) (individual) [SDGT] (Linked To: ISLAMIC ARMY). -to- AL-KAWARI, ‘Abd al-Latif Bin ‘Abdallah Salih Muhammad (a.k.a. AL-KAWARI, ‘Abd-al-Latif ‘Abdallah; a.k.a. AL-KAWARI, ‘Abd-al-Latif ‘Abdallah Salih; a.k.a. AL-KAWWARI, ‘Abd-al-Latif ‘Abdallah; a.k.a. AL-KUWARI, ‘Abd-al-Latif ‘Abdallah Salih; a.k.a. “Abu Ali al-Kawari”), al-Laqtah, Qatar; DOB 28 Sep 1973; nationality Qatar; Passport 01020802 (Qatar); alt. Passport 00754833 (Qatar) issued 20 May 2007; alt. Passport 00490327 (Qatar) issued 28 Jul 2001; National ID No. 27363400684 (Qatar) (individual) [SDGT] (Linked To: AL QA’IDA).

ISLAMIC ARMY (a.k.a. AL QAEDA; a.k.a. AL QA’IDA; a.k.a. AL QAIDA; a.k.a. AL-JIHAD; a.k.a. EGYPTIAN AL-JIHAD; a.k.a. EGYPTIAN ISLAMIC JIHAD; a.k.a. INTERNATIONAL FRONT FOR FIGHTING JEWS AND CRUSADES; a.k.a. ISLAMIC ARMY FOR THE LIBERATION OF HOLY SITES; a.k.a. ISLAMIC SALVATION FOUNDATION; a.k.a. NEW JIHAD; a.k.a. THE BASE; a.k.a. THE GROUP FOR THE PRESERVATION OF THE HOLY SITES; a.k.a. THE ISLAMIC ARMY FOR THE LIBERATION OF THE HOLY PLACES; a.k.a. THE JIHAD GROUP; a.k.a. THE WORLD ISLAMIC FRONT FOR JIHAD AGAINST JEWS AND CRUSADERS; a.k.a. USAMA BIN LADEN NETWORK; a.k.a. USAMA BIN LADEN ORGANIZATION) [FTO] [SDGT] [SDT]. -to- AL QA’IDA (a.k.a. AL QAEDA; a.k.a. AL QAIDA; a.k.a. AL-JIHAD; a.k.a. EGYPTIAN AL-JIHAD; a.k.a. EGYPTIAN ISLAMIC JIHAD; a.k.a. INTERNATIONAL FRONT FOR FIGHTING JEWS AND CRUSADES; a.k.a. ISLAMIC ARMY; a.k.a. ISLAMIC ARMY FOR THE LIBERATION OF HOLY SITES; a.k.a. ISLAMIC SALVATION FOUNDATION; a.k.a. NEW JIHAD; a.k.a. THE BASE; a.k.a. THE GROUP FOR THE PRESERVATION OF THE HOLY SITES; a.k.a. THE ISLAMIC ARMY FOR THE LIBERATION OF THE HOLY PLACES; a.k.a. THE JIHAD GROUP; a.k.a. THE WORLD ISLAMIC FRONT FOR JIHAD AGAINST JEWS AND CRUSADERS; a.k.a. USAMA BIN LADEN NETWORK; a.k.a. USAMA BIN LADEN ORGANIZATION) [FTO] [SDGT] [SDT].

and this listing from the Burundi sanctions:

NIYONZIMA, Joseph (a.k.a. NIJONZIMA, Joseph; a.k.a. NIYONZIMA, Mathias Joseph; a.k.a. NIYONZIMA, Salvator; a.k.a. “Kazungu”), Kinanira III, Kinindo, Bujumbura 257, Burundi; DOB 17 May 1960; alt. DOB 17 Jun 1960; alt. DOB 02 Jan 1967; alt. DOB 06 Mar 1956; POB Bukeye, Burundi; alt. POB Kanyosha Commune, Mubimbi, Bujumbura-Rural Province, Burundi; nationality Burundi; Passport OP0053090 (Burundi); alt. Passport OP0000185 (Burundi) issued 28 Jul 2011 expires 28 Jul 2016 (individual) [BURUNDI]. -to- NIYONZIMA, Joseph (a.k.a. NIJONZIMA, Joseph; a.k.a. NIYONZIMA, Mathias; a.k.a. NIYONZIMA, Salvator; a.k.a. “Kazungu”); DOB 02 Jan 1967; alt. DOB 06 Mar 1956; POB Kanyosha Commune, Mubimbi, Bujumbura-Rural Province, Burundi (individual) [BURUNDI].

were modified.

Link:

Filed under: Burundi sanctions, OFAC Updates, Sanctions Lists, Terrorism, ZImbabwe Sanctions

E. Sanctions Related to Gold and Other Precious Metals

Commitment:

Section 4.5 of Annex II and section 17.1 of Annex V of the JCPOA provide for the lifting, on
Implementation Day, of secondary sanctions that apply to non-U.S. persons with respect to Iran’s
trade in gold and other precious metals and the provision of associated services for such trade.

Implementation:

To effectuate the lifting of these sanctions on Implementation Day, the USG, in addition to
removing certain individuals and entities from the SDN List, FSE List, and NS-ISA List as
described in section III below, took the following steps:

Correspondent or Payable-Through Account Sanctions:

a. Waived the imposition of correspondent or payable-through account sanctions
under: section 1245(d)(1) of NDAA 2012 (for significant financial transactions by
FFIs with the CBI)52; section 1245(c) of IFCA (for significant financial
transactions by FFIs for the sale, supply, or transfer to or from Iran of precious
metals); and section 1247(a) of IFCA.53

b. Revoked E.O. 13645, including the correspondent or payable-through account
sanctions under subsection 3(a)(i) (for significant transactions by FFIs on behalf
of any Iranian person on the SDN List or any other person included on the SDN
List whose property and interests in property are blocked pursuant to subsection
2(a)(i) of E.O. 13645 or E.O. 13599).54

c. Committed to refrain from imposing sanctions under section 561.203(a) of the
IFSR for transactions by FFIs with the CBI that are consistent with the waiver of
section 1245(d)(1) of NDAA 2012.

Blocking Sanctions:

a. Waived the imposition of blocking sanctions under section 1244(c)(1) of IFCA55
(with respect to non-U.S. persons who knowingly provide significant financial,
material, technological, or other support to, or goods or services in support of any
activity or transaction on behalf of or for the benefit of a person determined to be
part of the energy, shipping, or shipbuilding sectors of Iran or to operate a port in Iran, or Iranian individuals or entities set forth in Attachment 3 to Annex II of the
JCPOA).56

b. Revoked: E.O. 13622, including the blocking sanctions under section 5(a) (with
respect to persons who have materially assisted, sponsored, or provided financial,
material, or technological support for, or goods or services in support of, NIOC,
NICO, or the CBI, or the purchase or acquisition of U.S. bank notes or precious
metals by the Government of Iran); and E.O. 13645, including subsection 2(a)(i)
(with respect to persons who have materially assisted, sponsored, or provided
financial, material, or technological support for, or goods or services to or in
support of, any Iranian person included on the SDN List or any other person
included on the SDN List whose property and interests in property are blocked
pursuant to subsection 2(a)(i) of E.O. 13645 or E.O. 13599).57

3. Menu-based Sanctions:

a. Waived the imposition of menu-based sanctions under: section 1245(a)(1)(A) of
IFCA (with respect to non-U.S. persons who sell, supply, or transfer to or from
Iran precious metals); and section 1246(a) of IFCA58 (for non-U.S. persons who
provide underwriting services, insurance, or reinsurance in connection with
activities involving Iran that are described in sections 17.1 to 17.2 and 17.5 of
Annex V of the JCPOA, or to or for any individual or entity whose property and
interests in property are blocked solely pursuant to E.O. 13599).

See section III for an overview of the sanctions list removals that occurred on Implementation
Day and section VI for an overview of the waiver determinations and findings issued in
connection with the JCPOA.

Effects of the lifting of sanctions related to gold and other precious metals:

As a result of the lifting of sanctions specified in section 4.5 of Annex II and section 17.1 of
Annex V of the JCPOA and described in this section, beginning on Implementation Day such
sanctions, including sanctions on associated services, do not apply to non-U.S. persons who sell,
supply, export, or transfer, directly or indirectly, to or from Iran, gold and other precious metals,
or conduct or facilitate a financial transaction or provide services for the foregoing, including
any security, insurance, and transportation.

For additional information on the sanctions lifting related to Iran’s trade in gold and other
precious metals discussed in this subsection, please see section F of the JCPOA FAQs.

Filed under: Guidance, Iranian Sanctions, Joint Comprehensive Plan of Action (JCPOA) Updates, OFAC Updates, Sanctions Regulations

F. Sanctions Related to Software and Metals

Commitment:

Section 4.6 of Annex II and section 17.2 of Annex V of the JCPOA provide for the lifting, on
Implementation Day, of secondary sanctions that apply to non-U.S. persons with respect to trade
with Iran in graphite, raw or semi-finished metals such as aluminum and steel, coal, and software
for integrating industrial processes, in connection with activities consistent with the JCPOA,
including trade with individuals and entities set forth in Attachment 3 to Annex II of the JCPOA
and the provision of associated services for each of the categories above.

Implementation:

To effectuate the lifting of these sanctions on Implementation Day, the USG, in addition to
removing certain individuals and entities from the SDN List, FSE List, and NS-ISA List as
described in section III below, took the following steps:

1. Correspondent and Payable-Through Account Sanctions:

a. Waived the imposition of correspondent or payable-through account sanctions
under: section 1245(d)(1) of NDAA 2012 (for significant financial transactions by
FFIs with the CBI);59 section 1244(d)(2) of IFCA (for significant financial
transactions by FFIs for the sale, supply, or transfer to or from Iran of significant
goods or services used in connection with the energy, shipping, or shipbuilding
sectors of Iran, including with NIOC, NITC, and IRISL); section 1245(c) of IFCA
(for significant financial transactions by FFIs for the sale, supply, or transfer to or
from Iran of specified materials (graphite, raw or semi-finished metals such as
aluminum and steel, coal, and software for integrating industrial processes) that
are within the scope of the waivers under section 1245(a)(1) of IFCA, as
described in section VI below); and section 1247(a) of IFCA.60

b. Revoked E.O. 13645, including the correspondent or payable-through account
sanctions under subsection 3(a)(i) (for significant transactions by FFIs on behalf
of any Iranian person on the SDN List or any other person included on the SDN
List whose property and interests in property are blocked pursuant to subsection
2(a)(i) of E.O. 13645 or E.O. 13599).61

c. Committed to refrain from imposing sanctions under section 561.203(a) of the
IFSR for transactions by FFIs with the CBI that are consistent with the waiver of
section 1245(d)(1) of NDAA 2012.

Blocking Sanctions

a. Waived the imposition of blocking sanctions under IFCA section 1244(c)(1)62
(with respect to non-U.S. persons who knowingly provide significant financial,
material, technological, or other support to, or goods or services in support of any
activity or transaction on behalf of or for the benefit of a person determined to be
part of the energy, shipping, or shipbuilding sectors of Iran or to operate a port in
Iran, or Iranian individuals or entities set forth in Attachment 3 to Annex II of the
JCPOA).63

b. Revoked E.O. 13622, including the blocking sanctions under section 5(a) (with
respect to persons who have materially assisted, sponsored, or provided financial,
material, or technological support for, or goods or services in support of, NIOC,
NICO, or the CBI, or the purchase or acquisition of U.S. bank notes or precious
metals by the Government of Iran); and E.O. 13645, including the blocking
sanctions under subsection 2(a)(i) (with respect to persons who have materially
assisted, sponsored, or provided financial, material, or technological support for,
or goods or services to or in support of, any Iranian person included on the SDN
List or any other person included on the SDN List whose property and interests in
property are blocked pursuant to subsection 2(a)(i) of E.O. 13645 or E.O.
13599).64

Menu-based Sanctions:

a. Waived the imposition of menu-based sanctions under: section 1244(d)(1) of
IFCA (with respect to non-U.S. persons who knowingly sell, supply, or transfer to
or from Iran significant goods or services used in connection with the energy,
shipping, or shipbuilding sectors of Iran, including with NIOC, NITC, and
IRISL); section 1245(a)(1)(B)-(C) of IFCA (with respect to non-U.S. persons who
sell, supply, or transfer to or from Iran specified materials (graphite, raw or semi-
finished metals such as aluminum and steel, coal, and software for integrating
industrial processes), subject to certain limitations as described in section VI
below); section 1246(a) of IFCA65 (for non-U.S. persons who provide
underwriting services, insurance, or reinsurance in connection with activities
involving Iran that are described in sections 17.1 to 17.2 and 17.5 of Annex V of
the JCPOA, or to or for any individual or entity whose property and interests in
property are blocked solely pursuant to E.O. 13599).

See section III for an overview of the sanctions list removals that occurred on Implementation
Day and section VI for an overview of the waiver determinations and findings issued in
connection with the JCPOA.

Effects of the lifting of sanctions relating to software and metals:

As a result of the lifting of sanctions specified in section 4.6 of Annex II and sections 17.1 to
17.2 of Annex V of the JCPOA and described in this section, beginning on Implementation Day
such sanctions, including sanctions on associated services, do not apply to non-U.S. persons who
sell, supply, or transfer, directly or indirectly, graphite, raw or semi-finished metals such as
aluminum and steel, coal, and software for integrating industrial processes, to or from Iran in
connection with activities consistent with the JCPOA, including trade with individuals and
entities set forth in Attachment 3 to Annex II of the JCPOA, and the sale, supply, or transfer of
such materials to the energy, petrochemical, shipping, and shipbuilding sectors of Iran, and
Iranian ports, or conduct or facilitate a financial transaction or provide services for the foregoing,
including insurance and reinsurance.

For additional information on the sanctions lifting related to Iran’s trade in software and metals
discussed in this subsection, please see section G of the JCPOA FAQs.

Filed under: Guidance, Iranian Sanctions, Joint Comprehensive Plan of Action (JCPOA) Updates, OFAC Updates, Sanctions Regulations

G. Sanctions Related to the Automotive Sector

Commitment:

Section 4.7 of Annex II and section 17.1 of Annex V of the JCPOA provide for the lifting, on
Implementation Day, of secondary sanctions that apply to non-U.S. persons with respect to the
sale, supply, or transfer of goods or services used in connection with Iran’s automotive sector and
the provision of associated services for such activity.

Implementation:

To effectuate the lifting of these sanctions on Implementation Day, the USG, in addition to
removing certain individuals and entities from the SDN List, FSE List, and NS-ISA List as
described in section III below, took the following steps:

1. Correspondent or Payable-Through Account Sanctions:

a. Waived the imposition of correspondent or payable-through account sanctions
under: section 1245(d)(1) of NDAA 2012 (for significant financial transactions by
FFIs with the CBI)66; section 1245(c) of IFCA (for significant financial
transactions by FFIs for the sale, supply, or transfer to or from Iran of precious
metals or specified materials (graphite, raw or semi-finished metals such as
aluminum and steel, coal, and software for integrating industrial processes) that
are within the scope of the waivers under section 1245(a)(1) of IFCA, as
described in section VI below); and section 1247(a) of IFCA.67

b. Revoked E.O. 13645, including the correspondent or payable-through account
sanctions under subsection 3(a)(i) (for significant transactions by FFIs on behalf
of any Iranian person on the SDN List or any other person included on the SDN
List whose property and interests in property are blocked pursuant to subsection
2(a)(i) of E.O. 13645 or E.O. 13599) and subsection 3(a)(ii) (for significant
transactions by FFIs for the sale, supply, or transfer to Iran of significant goods or
services used in connection with the automotive sector of Iran).68

c. Committed to refrain from imposing sanctions under section 561.203(a) of the
IFSR for transactions by FFIs with the CBI that are consistent with the waiver of
section 1245(d)(1) of NDAA 2012.

Blocking Sanctions:

a. Waived the imposition of blocking sanctions under section 1244(c)(1) of IFCA69
(with respect to non-U.S. persons who knowingly provide significant financial,
material, technological, or other support to, or goods or services in support of any
activity or transaction on behalf of or for the benefit of a person determined to be
part of the energy, shipping, or shipbuilding sectors of Iran or to operate a port in
Iran, or Iranian individuals or entities set forth in Attachment 3 to Annex II of the
JCPOA).70

b. Revoked: E.O. 13622, including the blocking sanctions under section 5(a) (with
respect to persons who have materially assisted, sponsored, or provided financial,
material, or technological support for, or goods or services in support of, NIOC,
NICO, or the CBI, or the purchase or acquisition of U.S. bank notes or precious
metals by the Government of Iran); and E.O. 13645, including the blocking
sanctions under subsection 2(a)(i) (with respect to persons who have materially
assisted, sponsored, or provided financial, material, or technological support for,
or goods or services to or in support of, any Iranian person included on the SDN
List or any other person included on the SDN List whose property and interests in
property are blocked pursuant to subsection 2(a)(i) of E.O. 13645 or E.O.
13599).71

Menu-based Sanctions:

a. Waived the imposition of menu-based sanctions under: sections 1245(a)(1)(B),
1245(a)(1)(C)(i)(II), and 1245(a)(1)(C)(ii)(II) of IFCA (with respect to non-U.S.
persons who sell, supply, or transfer to or from Iran specified materials (graphite,
raw or semi-finished metals such as aluminum and steel, coal, and software for
integrating industrial processes), subject to certain limitations as described in section VI below); and section 1246(a) of IFCA72 (for non-U.S. persons who
provide underwriting services, insurance, or reinsurance in connection with
activities involving Iran that are described in sections 17.1 to 17.2 and 17.5 of
Annex V of the JCPOA, or to or for any individual or entity whose property and
interests in property are blocked solely pursuant to E.O. 13599).

b. Revoked E.O. 13645, including the menu-based sanctions under section 5 (for
non-U.S. persons engaging in significant transactions for the sale, supply, or
transfer to Iran of significant goods or services used in connection with the
automotive sector of Iran).

See section III for an overview of the sanctions list removals that occurred on Implementation
Day and section VI for an overview of the waiver determinations and findings issued in
connection with the JCPOA.

Effects of the lifting of sanctions related to the automotive sector:

As a result of the lifting of sanctions specified in section 4.7 of Annex II and section 17.1 of
Annex V of the JCPOA and described in this section, beginning on Implementation Day such
sanctions, including sanctions on associated services, do not apply to non-U.S. persons who
conduct or facilitate financial or other transactions for the sale, supply, or transfer to Iran of
goods and services used in connection with the automotive sector of Iran.

For additional information on the sanctions lifting related to Iran’s automotive sector discussed
in this subsection, please see section H of the JCPOA FAQs.

Filed under: Guidance, Iranian Sanctions, Joint Comprehensive Plan of Action (JCPOA) Updates, OFAC Updates, Sanctions Regulations

III. Sanctions List Removals

In addition to the measures described above, to implement its commitments under the JCPOA,
on Implementation Day, the USG removed the individuals and entities specified in Attachment 3
to Annex II of the JCPOA from the SDN List, FSE List, and/or NS-ISA List, as appropriate.73
See Attachment 3 to Annex II of the JCPOA for the list of individuals and entities that were
removed from these lists on Implementation Day. OFAC published information regarding its
actions to give effect to these removals on its website on Implementation Day, and will
subsequently publish a notice of the removal actions in the Federal Register.74

A. Non-applicability of certain secondary sanctions authorities

As a result of these removals, beginning on Implementation Day, non-U.S. persons are no longer
subject to secondary sanctions for engaging in transactions with the individuals and entities set
out in Attachment 3 to Annex II of the JCPOA, including the CBI and other Iranian financial
institutions, provided that the transactions do not involve conduct described in sections VII.B-C
below or individuals or entities who remain or are placed on the SDN List. Those individuals
and entities set out in Attachment 3 to Annex II of the JCPOA that were previously designated
for sanctions have had those designations removed.75 In addition, all individuals and entities
listed in Attachment 3 to Annex II of the JCPOA were removed from the SDN List and/or, where
applicable, the FSE List and the NS-ISA List.76 As a result of these actions, the following
statutory sanctions authorities will no longer apply to transactions with these individuals and
entities:

Section 104(c)(2)(E)(ii)(I) of CISADA (correspondent or payable-through account
sanctions with respect to FFIs that knowingly facilitate a significant transaction or
transactions or provide significant financial services for a person whose property or
interests in property are blocked in connection with Iran’s proliferation of WMD or their
means of delivery);77

Section 1245(d) of NDAA 2012 (correspondent or payable-through account sanctions for
significant financial transactions by FFIs with a designated Iranian financial institution);

Section 1244(c)(1) of IFCA (blocking sanctions with respect to persons who knowingly
provide significant financial, material, technological, or other support to, or goods or
services in support of any activity or transaction on behalf of or for the benefit of any
Iranian person on the SDN List, other than an Iranian financial institution whose property
and interests in property are blocked solely pursuant to E.O. 13599);

Section 1246(a)(1)(B)(iii)(I) of IFCA (menu-based sanctions with respect to persons who
knowingly provide underwriting services or insurance or reinsurance to or for any person designated for the imposition of sanctions in connection with Iran’s proliferation of
WMD or their means of delivery);78 and

Section 1247(a) of IFCA (correspondent or payable-through account sanctions with
respect to FFIs that knowingly facilitate a significant financial transaction on behalf of
any Iranian person on the SDN List, other than an Iranian financial institution whose
property and interests in property are blocked solely pursuant to E.O. 13599).

B. Continued blocking under E.O. 13599 and section 560.211 of the ITSR

Further, even after Implementation Day, individuals and entities meeting the definition of the
Government of Iran or an Iranian financial institution, as those terms are defined in sections
560.304 and 560.324 of the ITSR, remain persons whose property and interests in property are
blocked pursuant to E.O. 13599 and section 560.211 of the ITSR. As a result, U.S. persons
continue to be broadly prohibited from engaging in transactions or dealings with these
individuals and entities unless such transactions or dealings are exempt from regulation or
authorized by OFAC. U.S. persons also continue to have an obligation to block the property and
interests in property of all individuals and entities that meet the definition of the Government of
Iran or an Iranian financial institution, regardless of whether the individual or entity has been
identified by OFAC as meeting those definitions. Individuals and entities that have been
previously identified by OFAC as meeting the definition of the Government of Iran or an Iranian
financial institution are marked with an asterisk in Attachment 3 to Annex II of the JCPOA.
Following Implementation Day, these individuals and entities continue to meet the relevant
definitions and continue to be persons whose property and interests in property are blocked
pursuant to E.O. 13599 and section 560.211 of the ITSR.79 To assist U.S. persons in meeting
their primary sanctions obligations under the ITSR with respect to these persons, OFAC has
made available on its website a list of persons identified as blocked solely pursuant to E.O.
13599 (E.O. 13599 List).

Please be advised that, under the ITSR, U.S. persons continue to have an obligation to block the
property and interests in property of individuals and entities listed in Attachment 3 to Annex II of
the JCPOA that do not have an asterisk next to their name and are not included on the E.O.
13599 List if such persons meet the definition of either the Government of Iran or an Iranian
financial institution as set forth in section 560.304 or 560.324 of the ITSR, respectively.

Non-U.S. persons will not be subject to secondary sanctions for engaging in transactions with the
individuals and entities listed on the E.O. 13599 List, provided that the transactions do not
involve conduct described in sections VII.B-C below or individuals or entities who remain or are
placed on the SDN List. See section III.A above.

For additional information on the sanctions list removals discussed in this section, please see
section I of the JCPOA FAQs.

Filed under: Guidance, Iranian Sanctions, Joint Comprehensive Plan of Action (JCPOA) Updates, OFAC Updates, Sanctions Regulations

On Monday, OFAC agreed to a settlement with Barclays Bank for 159 violations of the Zimbabwe sanctions program. The amount of the settlement is rather prosaic for this day and age: $2,485,890. The conduct occured between 2008 and 2013 and the total amount of the violations only totaled $3,375,617, with a base penalty of $5,029,000 for non-voluntarily self-disclosed non-egregious violations.

But here’s the thing: the transactions were “ for or on behalf of corporate customers of Barclays Bank of Zimbabwe Limited that were owned 50 percent or more, directly or indirectly, by a person identified on OFAC’s List of Specially Designated Nationals and Blocked Persons.” And, in case it wasn’t crystal-clear, this section from the enforcement information makes the regulatory expectation plain (highlighting mine):

This settlement demonstrates that an enforcement response may be particularly appropriate, even when an individual or entity is not included on the SDN List, in response to apparent violations in which: (a) the apparent violator is an institution that maintains direct customer relationships for entities that are beneficially owned, directly or indirectly, 50 percent or more by one or more SDNs, and is processing or routing transactions to or through the United States on behalf of such customers; (b) the institution’s own records clearly demonstrate or otherwise clarify the SDN ownership of the customer, but the institution failed to act on the information; and/or (c) information concerning the SDN ownership of the customer is publicly available and allows intermediary banks to identify and block such transactions.

This enforcement action highlights the importance for institutions with operations in countries with a significant presence of persons (individuals and entities) on the SDN List to take appropriate measures to ensure compliance with U.S. economic sanctions when processing transactions for or on behalf of their customers to, through, or within the United States.

I’ll leave it to the readers to paw through the details of the violations. But, OFAC’s thinking about how the penalty amount was calculated is always interesting:

OFAC found the following to be aggravating factors in this case:

although Barclays attempted to comply with OFAC sanctions despite various constraints imposed by the local Zimbabwean authorities, Barclays failed to implement adequate controls to prevent the apparent violations from occurring despite numerous warning signs that its conduct could lead to a violation of U.S. sanctions laws;

multiple business lines and personnel within Barclays, including supervisory and management staff in the bank’s Compliance and Audit functions, had actual knowledge or reason to know of the conduct that led to the apparent violations (including the bank’s awareness of the limitations of the systems used by BBZ with respect to capturing full information concerning the beneficial ownership of certain of its corporate customers);

Barclays processed 159 funds transfers totaling approximately $3,375,617 that conferred economic benefit to, and provided indirect access to the U.S. financial system for, blocked persons, causing harm to the Zimbabwe sanctions program and its associated policy objectives;

Barclays is a large and commercially sophisticated international financial institution; and

Barclays’ compliance program was inadequate to identify BBZ’s customers as blocked persons and/or prevent the apparent violations from occurring.

OFAC considered the following to be mitigating factors:

Barclays has not received a penalty notice or Finding of Violation in the five years preceding the earliest date of the transactions giving rise to the apparent violations;

Barclays took remedial action in response to the apparent violations; and

Barclays substantially cooperated with OFAC’s investigation by submitting detailed and organized information, and by executing a statute of limitations tolling agreement and an extension to the agreement.

OFAC also considered the fact that the prohibited entities were not publicly identified or designated and included on the SDN List at the time that Barclays processed transactions for or on their behalf.

Lastly, I want to point out that commercial vendors have done this research, which is a pretty massive effort, especially because of the need to look below 50% because of the aggregation aspect of the 50% Rule. While I have strayed away from promoting any products for the last 3 years, I will make an exception here. My employer, Dow Jones Risk and Compliance, has been doing this research for well over a year, starting with the Ukraine-related sanctions program. That program alone found on the order of 5100 entities (forget the exact figure) where there was board or voting control, or at least 10% ownership by someone formally listed on the SDN or Sectoral Sanction Identification List, or their EU equivalents – in over 80 countries. We are now approaching 7000 total entities across all sanctions programs, and we’re not done yet (but should be soon). Considering this enforcement action, finding a ready-made database of 50% Rule entities is more urgent than ever and, given the number of entities my firm has identified, probably not a research effort one should embark on themselves.

Links:

OFAC Enforcement Information

Filed under: Enforcement Actions, OFAC Updates, Uncategorized, ZImbabwe Sanctions

IV. Other Trade Measures

Commitment:

Pursuant to section 5 of Annex II and section 17.5 of Annex V of the JCPOA, the USG
committed to license three categories of activity that would otherwise be prohibited under the
ITSR, provided that relevant transactions do not involve individuals or entities on the SDN List
and are otherwise consistent with applicable U.S. laws and regulations.80

Implementation:

To fulfill these commitments, OFAC has issued: (i) a Statement of Licensing Policy (SLP)
allowing for the case-by-case licensing of the export, reexport, sale, lease, or transfer to Iran of
commercial passenger aircraft, spare parts and components for such aircraft, and associated
services, all for exclusively commercial passenger aviation; (ii) a general license authorizing
U.S.-owned or -controlled foreign entities to engage in certain activity with Iran that is consistent
with the JCPOA; and (iii) a general license authorizing the importation into the United States of
Iranian-origin carpets and foodstuffs, including pistachios and caviar.

A. Statement of Licensing Policy for Activities Related to the Export or Reexport
to Iran of Commercial Passenger Aircraft and Related Parts and Services
(SLP)

OFAC has issued a SLP, effective on Implementation Day, which establishes a favorable
licensing policy regime through which U.S. persons and, where there is a nexus to U.S.
jurisdiction, non-U.S. persons may request specific authorization from OFAC to engage in
transactions for the (i) export, reexport, sale, lease or transfer to Iran of commercial passenger
aircraft for exclusively civil aviation end use, (ii) export, reexport, sale, lease or transfer to Iran
of spare parts and components for commercial passenger aircraft; and (iii) provision of
associated services, including warranty, maintenance, and repair services and safety-related
inspections, for all the foregoing, provided that licensed items and services are used exclusively
for commercial passenger aviation.81 Any export, reexport, or transfer of U.S. export-controlled items must be consistent with U.S. legal requirements, including those under the Iran-Iraq Arms
Non-Proliferation Act and section 6(j) of the Export Administration Act. In addition, exports or
reexports to individuals and entities listed on the Department of Commerce’s Denied Persons
List and, in some cases, the Entity List will require separate authorization from the Department
of Commerce.

Please note that, should the United States determine that aircraft, goods, or services licensed for
export, reexport, sale, lease, or transfer to Iran under the SLP have been used for purposes other
than exclusively for commercial passenger aviation, or have been re-sold or re-transferred to
persons on the SDN List, the United States would view this as grounds to cease performing its
commitments under Section 5.1.1 of Annex II of the JCPOA in whole or in part. See section
5.1.1. of Annex II of the JCPOA.

For additional information on the SLP discussed in this subsection, please see section J of the
JCPOA FAQs.

B. General License Authorizing Activities by Non-U.S. Persons that are Owned
or Controlled by a U.S. Person

OFAC has issued General License H: Authorizing Certain Transactions Relating to Foreign
Entities Owned or Controlled by a United States Person (GL H), effective on Implementation
Day, authorizing U.S.-owned or -controlled foreign entities to engage in certain transactions
involving Iran that would otherwise be prohibited by section 560.215 of the ITSR. GL H does
not authorize U.S.-owned or -controlled foreign entities to engage in any transactions involving:
(1) the direct or indirect exportation or reexportation of goods, technology, or services from the
United States (without separate authorization from OFAC); (2) any transfer of funds to, from, or
through the U.S. financial system; (3) any individual or entity on the SDN List or any activity
that would be prohibited by non-Iran sanctions administered by OFAC if engaged in by a U.S.
person or in the United States; (4) any individual or entity identified on the FSE List; (5) unless
authorized by the U.S. Department of Commerce, activity prohibited by, or requiring a license
under, part 744 of the U.S. Export Administration Regulations (EAR) or a person whose export
privileges have been denied pursuant to part 764 or 766 of the EAR; (6) any military,
paramilitary, intelligence, or law enforcement entity of the Government of Iran, or any officials,
agents, or affiliates thereof; (7) any activity that is sanctionable under E.O. 12938 or 13382
(relating to Iran’s proliferation of weapons of mass destruction and their means of delivery,
including ballistic missiles); E.O. 13224 (relating to international terrorism); E.O. 13572 or
13582 (relating to Syria); E.O. 13611 (relating to Yemen); or E.O. 13553 or 13606, or section 2
or 3 of E.O. 13628 (relating to Iran’s commission of human rights abuses against its citizens);
and (8) any nuclear activity involving Iran that is subject to the procurement channel established
pursuant to paragraph 16 of UNSCR 2231 (2015) and section 6 of Annex IV of the Joint
Comprehensive Plan of Action of July 14, 2015 and that has not been approved through the
procurement channel process.

In addition, GL H authorizes U.S. persons to engage in certain activities otherwise prohibited by
the ITSR, namely, activities related to the establishment or alteration of corporate policies and
procedures to the extent necessary to allow U.S.-owned or -controlled foreign entities to engage in transactions involving Iran that are authorized under GL H, and making available to foreign
entities they own or control certain automated and globally integrated business support systems.
Please be advised, however, that with the exception of activities authorized in GL H, the
prohibition on facilitation by United States persons under section 560.208 of the ITSR will
remain in effect.

For additional information on GL H, please see section K of the JCPOA FAQs.

C. General License Authorizing the Importation of Iranian-Origin Carpets and

Foodstuffs

OFAC has issued a regulatory amendment to the ITSR, effective upon publication in the Federal
Register, to authorize the importation into the United States of Iranian-origin carpets and
foodstuffs, including pistachios and caviar. This authorization covers: (i) carpets and other
textile floor coverings and carpets used as wall hangings that are classified under chapter 57 or
heading 9706.00.0060 of the Harmonized Tariff Schedule of the United States (HTS),82 and

(ii) foodstuffs intended for human consumption that are classified under chapters 2-23 of the
HTS.83 Carpets and foodstuffs authorized for importation pursuant to the general license are still
subject to all other laws and regulations applicable to goods imported into the United States,
including generally applicable laws and regulations administered by other departments and
agencies, such as the Departments of Agriculture or Commerce, the Food and Drug
Administration, or Customs and Border Protection.

In addition, under an accompanying provision, U.S. depository institutions are authorized to
process letters of credit for payments for Iranian-origin carpets and foodstuffs, and U.S. persons
are authorized to act as brokers for the purchase or sale of Iranian-origin carpets and foodstuffs
authorized to be imported into the United States under the general license.

OFAC’s publication of this general license as an amendment to the ITSR fulfills the requirements
of section 103(d)(2)(A) of CISADA. In addition, the Secretary of State’s submission to the
appropriate congressional committees of a certification in writing that it is in the national interest
of the United States to provide an exception to the prohibition on the importation of Iranian-
origin goods to the extent required to implement the sanctions relief described in section 5.1.3 of
Annex II of the JCPOA and a report describing the reasons for this exception fulfills the
requirements of section 103(d)(2)(B) of CISADA.

For additional information on the general license for carpets and foodstuffs, please see section L
of the JCPOA FAQs.

Filed under: Guidance, Iranian Sanctions, Joint Comprehensive Plan of Action (JCPOA) Updates, Licenses, OFAC Updates, Sanctions Regulations

V. Termination of Executive Orders

To effectuate the lifting of sanctions set out in sections 4.1 to 4.7 of Annex II of the JCPOA and
described in section II of this Guidance, the United States committed in section 4 of Annex II and
section 17.4 of Annex V of the JCPOA to terminate E.O.s 13574, 13590, 13622, and 13645, and
sections 5-7 and 15 of E.O. 13628. To fulfill this commitment, on Implementation Day, the
President issued an E.O. (the “Termination E.O.”) revoking84 the following:

(i) E.O. 13574 (providing implementation authority for certain menu-based sanctions set
forth in ISA);

(ii) E.O. 13590 (providing for menu-based sanctions with respect to persons who
knowingly sell, lease or provide to Iran goods, services, technology, or support that
could directly and significantly contribute to the maintenance or expansion of Iran’s
domestic production of petrochemical products);

(iii) E.O. 13622 (providing for: sanctions on FFIs that knowingly facilitate significant
financial transactions with NIOC or NICO, or for the purchase or acquisition of
petroleum, petroleum products, or petrochemical products from Iran; sanctions on
persons who knowingly engage in significant transactions for the purchase or
acquisition of petroleum, petroleum products, or petrochemical products from Iran;
and sanctions on persons that have provided material support to NIOC, NICO, or the
CBI, or for the purchase or acquisition of U.S. bank notes or precious metals by the
Government of Iran);

(iv) E.O. 13645 (providing for sanctions relating to: the purchase or sale of the Iranian rial
(or contracts whose value is based on the Iranian rial); significant holdings of the
Iranian rial outside of Iran; Iran’s automotive sector; and persons that have provided
material support to any Iranian person on the SDN List or any other person included
on the SDN List whose property and interests in property are blocked pursuant to
subsection 2(a)(i) of E.O. 13645 or E.O. 13599 (other than an Iranian depository
institution whose property and interests in property are blocked solely pursuant to
E.O. 13599)); and

(v) Sections 5-7 and 15 of E.O. 13628 (providing for: (1) menu-based sanctions with
respect to persons who knowingly, between July 1, 2010, and August 10, 2012: sold,
leased, or provided to Iran goods, services, technology, information, or support that
could directly and significantly facilitate the maintenance or expansion of Iran’s
domestic production of refined petroleum products; sold or provided to Iran refined
petroleum products; or sold, leased, or provided to Iran goods, services, technology,
information, or support that could directly and significantly contribute to the
enhancement of Iran’s ability to import refined petroleum products and (2) certain
amendments to subsections 1(c)(iii), 1(d), and 2(b)(ii) of E.O.13622).

The Termination E.O. also continues in effect implementation provisions for aspects of certain
statutory sanctions that are outside the scope of the U.S. commitment to lift nuclear-related
sanctions under the JCPOA.85

Except as noted above, the Termination E.O. does not affect: (i) the national emergency declared
in E.O. 12957, which shall remain in place, (ii) any E.O. issued in furtherance of that national
emergency other than E.O.s 13574, 13590, 13622, 13628, and 13645, or (iii) the Iranian Assets
Control Regulations, 31 C.F.R. part 535. Further, the revocation of E.O.s 13574, 13590, 13622,
and 13645 and sections 5-7 and 15 of E.O. 13628 will not affect any enforcement action pending
or taken prior to the effective date of the Termination E.O., or any action or proceeding based on
any act committed prior to the date of the Termination E.O.86

For additional information on the Termination E.O., please see JCPOA FAQs A.8 and A.9.

Filed under: Guidance, Iranian Sanctions, Joint Comprehensive Plan of Action (JCPOA) Updates, OFAC Updates, Sanctions Regulations

On Wednesday, OFAC added the following person:

AL-HABABI, Nayf Salam Muhammad Ujaym (a.k.a. AL-HABABI, Nayef Salam Muhammad Ujaym; a.k.a. AL-QAHTANI AL-QATARI, Farouq; a.k.a. AL-QAHTANI, Faruq; a.k.a. AL-QAHTANI, Sheikh Farooq; a.k.a. AL-QATARI, Faruq; a.k.a. AL-QATARI, Sheikh Farooq; a.k.a. FAROUK, Shaykh Imran), Afghanistan; DOB 01 Jan 1979 to 31 Dec 1981; POB Saudi Arabia; nationality Qatar; alt. nationality Saudi Arabia; Passport 592667 (Qatar) issued 03 May 2007; Sheikh (individual) [SDGT] (Linked To: AL QA’IDA).

to the Specially Designated Nationals (SDN) List, under its anti-terror program.

Link:

Filed under: OFAC Updates, Sanctions Lists, Terrorism

Yesterday, OFAC added the following 3 individuals linked to ISIL/ISIS/Da’esh:

AL-BINALI, Turki Mubarak Abdullah Ahmad (a.k.a. AL BINALI, Turki Mubarak Abdullah; a.k.a. AL-BENALI, Turki; a.k.a. AL-BIN’ALI, Turki; a.k.a. AL-BIN’ALI, Turki Mubarak; a.k.a. “ABU DERGHAM”; a.k.a. “AL-ATHARI, Abu Human”; a.k.a. “AL-ATHARI, Abu Human Bakr ibn ‘Abd al-‘Aziz”; a.k.a. “AL-ATHARI, Abu-Bakr”; a.k.a. “AL-BAHRAYNI, Abu Hudhayfa”; a.k.a. “AL-MUDARI, Abu Khuzayma”; a.k.a. “AL-SALAFI, Abu Hazm”; a.k.a. “AL-SULAMI, Abu Sufyan”); DOB 03 Sep 1984; POB Al Muharraq, Bahrain; nationality Bahrain; Passport 2231616 (Bahrain) issued 02 Jan 2013 expires 02 Jan 2023; alt. Passport 1272611(Bahrain) issued 01 Apr 2003; Identification Number 840901356 (individual) [SDGT] (Linked To: ISLAMIC STATE OF IRAQ AND THE LEVANT).

AL-ZAHRANI, Faysal Ahmad ‘Ali (a.k.a. AL ZAHRANI, Faysal Ahmad Bin Ali; a.k.a. ALZAHRANI, Faisal Ahmed Ali; a.k.a. “AL-JAZRAWI, Abu-Sara”; a.k.a. “AL-SAUDI, Abu Sarah”; a.k.a. “AL-ZAHRANI, Abu-Sarah”; a.k.a. “ZAHRANI, Abu Sara”); DOB 19 Jan 1986; alt. DOB 18 Jan 1986; nationality Saudi Arabia; Passport K142736 (Saudi Arabia) issued 14 Jul 2011; alt. Passport G579315 (Saudi Arabia) (individual) [SDGT] (Linked To: ISLAMIC STATE OF IRAQ AND THE LEVANT).

JUAYTHINI, Husayn (a.k.a. ALJEITHNI, Hussein Mohammed Hussein; a.k.a. AL-JU’AITNI, Abu Mu’ath; a.k.a. AL-JU’AYTHINI, Husayn Muhamad Husayn; a.k.a. AL-JU’AYTHINI, Husayn Muhammad; a.k.a. AL-JU’AYTHINI, Husayn Muhammad Husayn; a.k.a. JU’AYTHINI, Husayn Muhammad Husayn); DOB 03 May 1977; POB Al-Nusayirat refugee camp, Gaza; Passport 0363464 (individual) [SDGT] (Linked To: ISLAMIC STATE OF IRAQ AND THE LEVANT).

to the SDN List under the anti-terrorism sanctions program.

Link:

Filed under: Islamic State/ISIS/ISIL, OFAC Updates, Sanctions Lists, Terrorism

And this is how it's all going to get done – and to enable the “snap-back” if Iran breaks its side of the deal:

VI. Waivers

Commitment:

Pursuant to the U.S. commitment in section 11 of Annex V of the JCPOA, on Adoption Day, the
Secretary of State issued waiver determinations and made findings with respect to certain
statutory sanctions provisions set out in section 4 of Annex II of the JCPOA.87 By their terms,
these waivers and findings were contingent in nature; they only took effect upon confirmation by
the Secretary of State that Iran had implemented the nuclear-related measures specified in
sections 15.1 to 15.11 of Annex V of the JCPOA, as verified by the IAEA (i.e., upon
Implementation Day).88

These waivers and findings, effective on January 16, 2016, waive the imposition of sanctions
under specified provisions of NDAA 2012 and IFCA and find it is vital to the national security
interests of the United States to issue waivers regarding the application of sanctions under
specified provisions of ISA and the TRA, all with respect to certain transactions and activities by
non-U.S. persons89 involving Iran, as set forth in section 4 of Annex II of the JCPOA and
described in section II above. In addition, the waiver determination under sections 1244(c)(1)
and 1246(a) of IFCA waives the imposition of sanctions with respect to transactions by U.S.
persons for the export, reexport, sale, lease, or transfer of commercial passenger aircraft and
related parts and services to Iran exclusively for commercial passenger aviation as set forth in
section 5.1.1 of the JCPOA, provided that OFAC has issued any required licenses.

Implementation:

To implement the U.S. commitments with respect to sanctions described in sections 17.1 to 17.3
and 17.5 of Annex V of the JCPOA, effective Implementation Day, the USG is waiving the

(i) sanctions under IFCA and NDAA 2012 and (ii) application of sanctions under TRA and ISA,
to the extent necessary to implement the JCPOA and excluding any transactions involving
persons on OFAC’s SDN List:

A. IFCA

1. Section 1244(c)(1) – to the extent required for transactions by non-U.S. persons (and, in
the case of commercial passenger aviation activities described in section IV.A above, U.S.
persons, provided that OFAC has issued any required licenses) on behalf of, or for the
benefit of: (i) a person determined to be part of the energy, shipping, or shipbuilding sectors of Iran, (ii) a person determined to operate a port in Iran; or (iii) Iranian
individuals and entities set forth in Attachment 3 to Annex II of the JCPOA;90

2. Section 1244(d) – to the extent required for transactions by non-U.S. persons for the sale,
supply, or transfer to or from Iran of goods or services used in connection with the 91
energy, shipping, or shipbuilding sectors of Iran, including NIOC, NITC, and IRISL;

3. Section 1244(h)(2) – to the extent required for FFIs to conduct or facilitate transactions
for the sale, supply, or transfer to or from Iran of natural gas;

4. Section 1245(a)(1)(A) – to the extent required for transactions by non-U.S. persons for
the sale, supply, or transfer to or from Iran of precious metals;

5. Section 1245(a)(1)(B)– to the extent required for transactions by non-U.S. persons for the
sale, supply, or transfer to or from Iran of materials described in section 1245(d) of IFCA
(graphite, raw or semi-finished metals such as aluminum and steel, coal, and software for
integrating industrial processes) determined to be (i) used by Iran as a medium for barter
swap, or any other exchange or transaction or (ii) listed as assets of the Government of
Iran for purposes of the national balance sheet of Iran;92

6. Section 1245(a)(1)(C) – to the extent required for transactions by non-U.S. persons for
the sale, supply, or transfer to or from Iran of materials described in section 1245(d) of
IFCA (graphite, raw or semi-finished metals such as aluminum and steel, coal, and
software for integrating industrial processes) if the material is (i) to be used in connection
with the energy, shipping, or shipbuilding sectors of Iran, or resold, retransferred, or
otherwise supplied to an end user in one or more such sectors; (ii) sold, supplied, or
transferred to any individual or entity blocked solely pursuant to E.O. 13599, or resold,
retransferred, or otherwise supplied to such an individual or entity; or (iii) determined
pursuant to section 1245(e)(3) of IFCA to be used as described in that section, or resold,
retransferred, or otherwise supplied for use in the nuclear program of Iran, provided that
the transactions do not involve:

(a) the sale, supply, or transfer of materials described in section 1245(d) that have
not been approved by the procurement channel established pursuant to paragraph 16 of UNSCR 2231 and section 6 of Annex IV of the JCPOA, in cases in which
the procurement channel applies; or

(b) the sale, supply, or transfer of materials described in section 1245(d) if the
material is sold, supplied, or transferred, or resold, retransferred, or otherwise
supplied directly or indirectly, for use in connection with the military or ballistic
missile program of Iran;93

7. Section 1245(c) – to the extent required for FFIs to conduct or facilitate transactions that
are within the scope of the waivers under section 1245(a)(1) of IFCA, as described in
sections VI.A.4-VI.A.6 above;

8. Sections 1246(a)(1)(A) – to the extent required for non-U.S. persons to provide
underwriting services or insurance or reinsurance in connection with activities involving
Iran that are within the scope of the JCPOA (as described in sections 17.1 to 17.2 and
17.5 of Annex V of the JCPOA);

9. Section 1246(a)(1)(B)(i) – to the extent required for non-U.S. persons to provide
underwriting services or insurance or reinsurance with respect to, or for the benefit of,
any activity in the energy, shipping, or shipbuilding sectors of Iran for which sanctions
are imposed under IFCA;

10. Section 1246(a)(1)(B)(ii) – to the extent required for non-U.S. persons to provide
underwriting services or insurance or reinsurance for transactions that are within the
scope of the waivers under section 1245(a)(1)(B) and (C) of IFCA as described in
paragraphs VI.A.5-VI.A.6 above;

11. Section 1246(a)(1)(C) – to the extent required for non-U.S. persons to provide
underwriting services or insurance or reinsurance with respect to or for any Iranian
person whose property and interests in property are blocked solely pursuant to E.O.
13599 and section 560.211 of the ITSR, including Iranian individuals and entities set
forth in Attachment 3 to Annex II of the JCPOA;

12. Section 1246(a) – to the extent required for U.S. persons to provide underwriting services
or insurance or reinsurance in connection with commercial passenger aviation activities
described in section IV.A above, provided that OFAC has issued any required licenses;
and

13. Section 1247(a) – to the extent required for FFIs to facilitate transactions on behalf of
Iranian individuals and entities set forth in Attachment 3 to Annex II of the JCPOA;

B. NDAA 2012

1. Section 1245(d)(1) – to the extent necessary to implement the JCPOA, including for FFIs
to conduct or facilitate transactions with the CBI covered by the U.S. commitments with
respect to sanctions described in sections 17.1 to 17.2 of Annex V of the JCPOA;94

C. TRA

1. Section 212(a) – to the extent required for transactions by non-U.S. persons95 for the
provision of underwriting services or insurance or reinsurance for NIOC, NITC, or a
successor entity to either company, in cases where the transactions are for activities
described in sections 4.2.1, 4.3, and 4.4 of Annex II of the JCPOA;

2. Section 213(a) – to the extent required for transactions by non-U.S. persons for the
purchase, subscription to, or facilitation of the issuance of sovereign debt of the
Government of Iran or debt or equity of an entity owned or controlled by the Government
of Iran, in cases where the transactions are for activities described in section 4.1.5 and
4.1.7 of Annex II of the JCPOA; and

D. ISA

1. ISA section 5(a) – to the extent required for transactions by non-U.S. persons related to:
(i) the development of petroleum resources of Iran; (ii) the production of refined
petroleum products in Iran; (iii) the exportation of refined petroleum products to Iran;
(iv) joint ventures with Iran relating to the development of petroleum resources outside of
Iran; (v) support for the development of petroleum resources and refined petroleum
products in Iran; (vi) the development and purchase of petrochemical products from Iran;
(vii) the transportation of crude oil from Iran; or (viii) the ownership, operation, or
control of a vessel used in a manner that conceals the Iranian origin of crude oil or
refined petroleum products transported on the vessel, in cases where the transactions are
for activities described in sections 4.2.1, 4.3.1, 4.3.2, 4.3.4, and 4.3.6 of Annex II of the
JCPOA.

Filed under: Guidance, Iranian Sanctions, Joint Comprehensive Plan of Action (JCPOA) Updates, OFAC Updates, Sanctions Regulations

Or… “What's left of US sanctions on Iran”…

VII.

Key U.S. Legal Authorities That Remain in Place After Implementation Day

A number of U.S. legal authorities that are outside the scope of the JCPOA and are directed
toward, or have been used to address, U.S. concerns with respect to, Iran remain in place after
Implementation Day. A non-exhaustive list of such authorities is set out below:

A. Trade Sanctions

1. Trade Embargo: The U.S. domestic trade embargo imposed on Iran under the
national emergency declared in E.O. 12957, as implemented through the ITSR, also referred to as U.S. primary sanctions, remains in place following Implementation Day. Pursuant to the ITSR and with limited exceptions,
persons, as defined in section 560.314 of the ITSR, continue to be broadly
prohibited from engaging in transactions or dealings directly or indirectly with
Iran or its government. In addition, non-U.S. persons continue to be prohibited
from knowingly engaging in conduct that seeks to evade U.S. restrictions on
transactions or dealings with Iran or that causes the export of goods or services
from the United States to Iran

Please note that, under the ITSR, the clearing of transactions involving Iran
through the U.S. financial system, including foreign branches of U.S. financial
institutions continues to be prohibited

2. Export Controls: U.S. controls on the exportation or reexportation of goods,
technology, and services to Iran imposed pursuant to the ITSR, including sections
560.204 and 560.205, as well as the Export Administration Regulations, 15 C.F.R.
parts 730-774 (EAR), and the International Traffic in Arms Regulations, 22 CFR
parts 120-130 (ITAR), remain in place. Pursuant to these authorities and unless
exempt from regulation or authorized under the relevant regulations, the
exportation or reexportation by a U.S. person or from the United States to Iran or
the Government of Iran, as well as the reexportation by non-U.S. persons of items
that contain 10 percent or more U.S.-controlled content with knowledge or reason
to know that the reexportation is intended specifically to Iran or the Government
of Iran, generally requires a license

B. Designation Authorities and Blocking Sanctions

In addition, the United States retains a number of authorities that are directed toward, or have
been used to address, U.S. concerns with respect to Iran. Generally, these authorities provide for
the imposition of blocking sanctions on persons meeting certain criteria or engaging in specified
conduct, as well as their support networks.

Designation authorities:

The activities targeted by these authorities include:

1. Support for terrorism: E.O. 13224 (blocking property and prohibiting transactions
with persons who commit, threaten to commit, or support terrorism);

2. Iran’s human rights abuses:

E.O.s 13553 and 13628 (implementing sections 105, 105A, and 105B of
CISADA (related to persons who are responsible for or complicit in
human rights abuses committed against the citizens of Iran; transfers of
goods or technologies to Iran that are likely to be used to commit serious
human rights abuses against the people of Iran; and persons who engage in
censorship or similar activities with respect to Iran)); and

E.O. 13606 (relating to the provision of information technology used to
further serious human rights abuses)

3. Proliferation of WMD and their means of delivery, including ballistic missiles: E.O.s 12938 and 13382

4. Support for persons involved in human rights abuses in Syria or for the
Government of Syria: E.O.s 13572 and 13582

5. Support for persons threatening the peace, security, or stability of Yemen: E.O.
13611

6. Transactions or activities described in section 1244(c)(1)(A) of IFCA if the
transaction involves any person on the SDN list (other than an Iranian financial
institution whose property and interests in property are blocked solely pursuant to
E.O. 13599): Section 1244(c)(1) of IFCA

7. Diversion of goods intended for the people of Iran: CISADA 105C, as added by
section 1249 of IFCA (relating to the diversion of goods, including agricultural
commodities, food, medicine, and medical devices, intended for the people of
Iran, or the misappropriation of proceeds from the sale or resale of such goods)

8. Knowingly and directly providing specialized financial messaging services to, or
knowingly enabling or facilitating direct or indirect access to such messaging
services for a financial, institution whose property or interests in property are
blocked in connection with Iran's proliferation of WMD or their means of 97
delivery, or Iran's support for international terrorism: Section 220 of the TRA;

9. Officials, agents, and affiliates of the IRGC: Section 301 of the TRA98 (providing
for the designation of officials, agents, or affiliates of the IRGC); and

10. Foreign sanctions evaders: E.O. 13608 (authorizing the imposition of prohibitions
on transactions or dealings by U.S. persons involving persons determined to have:
(i) violated, attempted to violate, conspired to violate, or caused a violation of
U.S. sanctions with respect to Iran or Syria (including sanctions imposed under
counter-proliferation or counter-terrorism authorities); or (ii) facilitated deceptive
transactions for or on behalf of any person subject to U.S. sanctions concerning
Iran or Syria).99

Blocking authorities:

The persons targeted by these authorities include:

1. The Government of Iran and Iranian Financial Institutions: E.O. 13599, section
217(a) of the TRA, section 560.211 of the ITSR; and

2. Islamic Republic of Iran Broadcasting and its president under section 105(c) of
CISADA: Section 1248 of IFCA.

C. Correspondent and Payable-through Account Sanctions

After Implementation Day, FFIs may be subject to correspondent or payable-through account
secondary sanctions for:

1. Knowingly facilitating a significant financial transaction with designated Iranian
financial institutions that remain or are placed on the SDN List (section 1245(d)
of NDAA 2012);

2. Knowingly facilitating a significant financial transaction on behalf of any Iranian
persons that remain or are placed on the SDN List (section 1247(a) of IFCA);

3. Knowingly facilitating a significant financial transaction or providing significant
financial services for any other person on the SDN List with the “[IFSR]”
identifying tag (i.e., the Islamic Revolutionary Guard Corps (IRGC) and any of its
designated officials, agents, or affiliates; individuals and entities designated
pursuant to E.O. 13382 in connection with Iran’s proliferation of WMD or their
means of delivery; and individuals and entities designated pursuant to E.O. 13224
in connection with Iran’s support for international terrorism) (section 104(c)(2)(E)
of CISADA);

4. Knowingly facilitating a significant financial transaction for the sale, supply, or
transfer to or from Iran of significant goods and services used in connection with
the energy, shipping, or shipbuilding sectors of Iran where the transactionsinvolve persons who remain or are placed on the SDN List (section 1244(d)(2) of
IFCA); or

5. Knowingly conducting or facilitating a significant financial transaction for the
sale, supply, or transfer to or from Iran of graphite, raw or semi-finished metals
such as aluminum and steel, coal, and software for integrating industrial processes
that have been determined pursuant to section 1245(e)(3) of IFCA to be used as
described in that section if the transactions involve (i) persons on the SDN List;
(ii) the sale, supply, or transfer of materials described in section 1245(d) of IFCA
that have not been approved by the procurement channel established pursuant to
paragraph 16 of UNSCR 2231 and section 6 of Annex IV of the JCPOA, in cases
in which the procurement channel applies; or (iii) the sale, supply, or transfer of
materials described in section 1245(d) of IFCA if the material is sold, supplied, or
transferred, or resold, retransferred, or otherwise supplied directly or indirectly,
for use in connection with the military or ballistic missile program of Iran (section
1245(c) of IFCA).

D. Menu-based Sanctions

After Implementation Day, menu-based secondary sanctions continue to attach to:

1. Persons who materially assist, sponsor, or provide financial, material, or
technological support for, or goods or services in support of: the IRGC or any of
its officials, agents, or affiliates blocked pursuant to IEEPA; persons that engage
in significant transactions with (i) any of the foregoing or (ii) persons subject to
financial sanctions pursuant to the UNSCRs that impose sanctions with respect to
Iran, or a person acting for or on behalf of, or owned or controlled by, such person
(section 302(a) of the TRA);

2. Non-U.S. persons who engage in transactions or activities described in sections
1244(d)(1) and 1246(a) of IFCA if the transactions involve persons on the SDN
List; and

3. Non-U.S. persons who sell, supply, or transfer directly or indirectly to or from
Iran graphite, raw or semi-finished metals such as aluminum and steel, coal, and
software for integrating industrial processes that have been determined pursuant
to section 1245(e)(3) of IFCA to be used as described in that section if the
transactions involve (i) persons on the SDN List; (ii) the sale, supply, or transfer
of materials described in section 1245(d) of IFCA that have not been approved by
the procurement channel established pursuant to paragraph 16 of UNSCR 2231
and section 6 of Annex IV of the JCPOA, in cases in which the procurement
channel applies; or (iii) the sale, supply, or transfer of materials described in
section 1245(d) of IFCA if the material is sold, supplied, or transferred, or resold,
retransferred, or otherwise supplied directly or indirectly, for use in connection
with the military or ballistic missile program of Iran (section 1245(a) of IFCA).

E. Non-Proliferation Sanctions

On Transition Day, the United States will seek such legislative action as may be appropriate to
terminate, or modify to effectuate the termination of, the nuclear proliferation-related statutory
sanctions set forth in paragraph 4.9 of Annex II of the JCPOA, including sanctions under the
Iran, North Korea and Syria Nonproliferation Act on the acquisition of nuclear-related
commodities and services for nuclear activities contemplated in the JCPOA, to be consistent with
the U.S. approach to other non-nuclear weapon states under the Treaty on the Non-Proliferation
of Nuclear Weapons. The JCPOA does not address the application of a number of generally-
applicable non-proliferation statutes related to transfers of proliferation-sensitive equipment and
technology, or statutes that provide for sanctions for activities that would be outside the scope of
the JCPOA.

F. Terrorism List Sanctions

Iran remains designated as a state sponsor of terrorism under relevant laws (section 6(j) of the
Export Administration Act; section 40 of the Arms Export Control Act; and section 620A of the
Foreign Assistance Act), and the JCPOA does not alter that designation. A number of different
sanctions laws and restrictions are keyed to this designation, including restrictions on foreign
assistance (22 U.S.C. § 2371), a ban on defense exports and sales (22 U.S.C. § 2780), controls on
exports of certain sensitive technology and dual-use items (50 U.S.C. App. § 2405), and various
financial and other restrictions.

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Filed under: Guidance, Iranian Sanctions, Joint Comprehensive Plan of Action (JCPOA) Updates, OFAC Updates, Sanctions Regulations

Last Tuesday, OFAC added the following 2 persons:

ROBERTO ORELLANA, Jose (Latin: ROBERTO ORELLANA, José) (a.k.a. “CHIBOLA”; a.k.a. “GORDO MAX”; a.k.a. “TIO SAM” (Latin: TÍO SAM); a.k.a. “TOLOLO”), Canton Cambio Chanmico, Calle Vieja, Casa #66, San Juan Opico, La Libertad, El Salvador; DOB 29 Jun 1973; Identification Number 011319137-3 (El Salvador) (individual) [TCO] (Linked To: MS-13).

ROMERO GARCIA, Dany Balmore (Latin: ROMERO GARCÍA, Dany Balmore) (a.k.a. “BIG BOY”; a.k.a. “D-BOY”), Pje. 6, Casa 11, Soyapango, San Salvador, El Salvador; DOB 26 Apr 1974; Identification Number 04237453-4 (El Salvador) (individual) [TCO] (Linked To: MS-13).

to the SDN List under the Transnational Criminal Organizations (TCO) sanctions program.

Link:

OFAC Enforcement Information

Filed under: OFAC Updates, Organized Crime Sanctions, Sanctions Lists

CGG Services SA agreed to a settlement of $614,250 for violating the Cuban Asset Control Regulations in new and exciting ways. First, one of the company’s US affiliates supplied goods to a number of vessels between 2010 and 2011 while these ships were in Cuban territorial waters. Secondly, the US company’s Venezuelan subsidiary processed seismic data from Cuba’s Exclusive Economic Zone on 5 occasions – which benefitted a Cuban firm.

The statutory maximum penalty for these non-egregious violations that were not voluntarily self-reported was $2,340,000 – which is $65,000 for each of 36 violations. And the base penalty was $975,000.

And how did OFAC get from $975,000 to $614,250? Child’s play:

CGG France acted with reckless disregard for U.S. sanctions requirements by exporting U.S.-origin goods to Cuban waters, especially after its U.S. affiliate informed it that such exports could be a violation of U.S. sanctions;
Veritas Geoservices acted with reckless disregard for U.S. sanctions requirements by performing data processing related to seismic surveys conducted in Cuban waters without determining if there was a Cuban interest in the data;
CGG France was aware of the conduct giving rise to the alleged violations because it knew where the vessels were located and the origin of the goods;
The underlying transactions had a total value of $2,758,701 and were related to oil exploration, which likely caused significant harm to U.S. sanctions program objectives by providing a substantial economic benefit to Cuba;
CGG France and its affiliated companies have not been the subject of a penalty notice or Finding of Violation from OFAC in the five years preceding the earliest date of the transactions giving rise to the alleged violations;
CGG France took some steps to avoid OFAC violations as part of its compliance program, including removing U.S. personnel and equipment for M/V Vantage prior to it entering Cuba’s territorial waters;
CGG France has adjusted its supply procedures to minimize the risk of future sanctions violations; and
CGGVeritas agreed to toll the statute of limitations and substantially cooperated with Enforcement’s investigation.

Link:

OFAC Enforcement Information

Filed under: Cuba Sanctions, Enforcement Actions, OFAC Updates, Settlements

Halliburton Atlantic Limited (HAL) and Halliburton Overseas Limited (HOL) exported goods and services to an oil and gas production consortium which had 5% ownership by Cuba Petroleo (aka Cupet), a state-owned Cuban firm. The value of the 19 invoices issued by Halliburton was $1,189,752.

The statutory maximum penalty for these voluntarily self-reported, non-egregious violations was $1,235,000, while the base penalty was $423,202.

The aggravating factors in OFAC’s decision:

HAL and HOL acted with reckless disregard for U.S. sanctions by conducting transactions for the benefit of a Consortium without conducting reasonable due diligence to determine who belonged to the Consortium and had a corresponding interest in the Concession;
HAL and HOL should have known that a Cuban entity belonged to the Consortium because the Consortium operator provided HAL with documents that showed that Cupet was a member, and there were other contemporaneous documents that stated Cupet held an interest in the Consortium, including a news article and a notice in an Angolan government registry;
Halliburton and its affiliated companies are sophisticated entities that regularly deal in oilfield goods and services around the world; and
Halliburton’s sanctions compliance program was inadequate because it did not include a procedure to screen all of the Consortium members.

and the mitigating factors:

HAL and HOL are eligible for up to 25 percent “first violation” mitigation because they have not been the subject of a penalty notice or Finding of Violation in the five years preceding the date of the earliest transaction giving rise to the apparent violations; and
Cupet’s interest in the Concession was only five percent, thus reducing the extent of the economic benefit provided to a sanctioned country.

Link:

Filed under: Cuba Sanctions, Enforcement Actions, OFAC Updates, Settlements

Last Wednesday, OFAC added the following persons:

CHOE, Chun-sik (a.k.a. CHOE, Chun Sik; a.k.a. CH’OE, Ch’un-sik), Korea, North; DOB 12 Oct 1954; nationality Korea, North (individual) [NPWMD] (Linked To: SECOND ACADEMY OF NATURAL SCIENCES).

HWANG, Pyong So (a.k.a. HWANG, Pyo’ng-so’), Korea, North; DOB 1940; Vice Chairman of the National Defense Commission (individual) [DPRK2] (Linked To: NATIONAL DEFENSE COMMISSION).

HYON, Gwang Il (a.k.a. HYON, Kwang Il), Korea, North; DOB 27 May 1961; nationality Korea, North; Department Director at the National Aerospace Development Administration (individual) [NPWMD] (Linked To: NATIONAL AEROSPACE DEVELOPMENT ADMINISTRATION).

KANG, Mun-kil (a.k.a. JIAN, WenJi), Korea, North; nationality Korea, North; Passport PS 472330208 (Korea, North) expires 04 Jul 2017 (individual) [NPWMD] (Linked To: NAMCHONGANG TRADING CORPORATION).

KIM, Song Chol (a.k.a. KIM, Hak Song); DOB 26 Mar 1968; alt. DOB 15 Oct 1970; nationality Korea, North; Passport 654120219 (Korea, North) expires 24 Feb 2019; alt. Passport 381420565 (Korea, North) expires 23 Nov 2016 (individual) [NPWMD] (Linked To: KOREA MINING DEVELOPMENT TRADING CORPORATION).

PAK, Chun Il, Egypt; DOB 28 Jul 1954; nationality Korea, North; Passport 563410091 (Korea, North); North Korean Ambassador to Egypt (individual) [DPRK2].

PAK, Yong Sik (a.k.a. PAK, Yo’ng-sik), Korea, North; DOB 1950; Member of the Workers’ Party of Korea Central Military Commission (individual) [DPRK2] (Linked To: WORKERS’ PARTY OF KOREA CENTRAL MILITARY COMMISSION).

RI, Man Gon, Korea, North; DOB 1945 (individual) [DPRK2].

RI, Yong Mu (a.k.a. RI, Yong-Mu), Korea, North; DOB 25 Jan 1925; POB South Pyo’ngan Province, Pyo’ngso’ng; Vice Chairman of the National Defense Commission (individual) [DPRK2] (Linked To: NATIONAL DEFENSE COMMISSION).

SON, Jong Hyok (a.k.a. SON, Min), Egypt; DOB 20 May 1980; nationality Korea, North (individual) [NPWMD] (Linked To: KOREA MINING DEVELOPMENT TRADING CORPORATION).

YU, Chol U, Korea, North; DOB 08 Aug 1959; Director, National Aerospace Development Administration (individual) [DPRK2] (Linked To: NATIONAL AEROSPACE DEVELOPMENT ADMINISTRATION).

and entities:

NATIONAL DEFENSE SCIENCE, Pyongyang, Korea, North [NPWMD].

MINISTRY OF ATOMIC ENERGY INDUSTRY, Haeun 2-Dong, Pyongchon District, Pyongyang, Korea, North [NPWMD].

NATIONAL AEROSPACE DEVELOPMENT ADMINISTRATION (a.k.a. “NADA”), Korea, North [NPWMD].

NATIONAL DEFENSE COMMISSION, Pyongyang, Korea, North [DPRK2].

WORKERS’ PARTY OF KOREA CENTRAL MILITARY COMMISSION, Pyongyang, Korea, North [DPRK2].

to the SDN List under its North Korean sanctions program. In addition, they updated the following records listed under the non-proliferation sanctions program:

NAMCHONGANG TRADING CORPORATION (a.k.a. NAM CHON GANG CORPORATION; a.k.a. NAMCHONGANG TRADING; a.k.a. NOMCHONGANG TRADING CO.; a.k.a. “NCG”), Pyongyang, Korea, North [NPWMD]. -to- NAMCHONGANG TRADING CORPORATION (a.k.a. KOREA NAMHUNG TRADING CORPORATION; a.k.a. NAM CHON GANG CORPORATION; a.k.a. NAMCHONGANG TRADING; a.k.a. NAMHUNG; a.k.a. NOMCHONGANG TRADING CO.; a.k.a. “NCG”), Pyongyang, Korea, North; Chilgol, Mangyongdae District, Pyongyang, Korea, North [NPWMD].

O, Kuk-Ryol (a.k.a. O, Ku’k-ryo’l); DOB 07 Jan 1930; POB Onso’ng County, North Hamgyo’ng Province, Democratic People’s Republic of Korea (individual) [NPWMD]. -to- O, Kuk-Ryol (a.k.a. O, Ku’k-ryo’l), Korea, North; DOB 07 Jan 1930; POB Onso’ng County, North Hambuk Province, Democratic People’s Republic of Korea; Vice Chairman of the National Defense Commission (individual) [NPWMD] [DPRK2](Linked To: NATIONAL DEFENSE COMMISSION).

Link: