November 7, 2019: OFAC adds 3 to Nicaragua sanctions, 1 to counter terror program

November 8, 2019, 7:30 am

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On Thursday, OFAC added the following persons:

AVELLAN MEDAL, Ramon Antonio, Bello Horizonte 6TA Etapa Nl 4, Managua, Nicaragua; DOB 11 Nov 1954; POB Jinotepe, Nicaragua; nationality Nicaragua; Gender Male; Passport A0008696 (Nicaragua) issued 17 Oct 2011 expires 17 Oct 2021; National ID No. 0411111540000Q (Nicaragua) (individual) [NICARAGUA] [NICARAGUA-NHRAA].

CAMPBELL HOOKER, Lumberto Ignacio, Entrada Principal Los Robles, 1 Abajo 1 Al Sur Casa 23, Managua, Nicaragua; DOB 03 Feb 1949; POB Raas, Nicaragua; nationality Nicaragua; Gender Male; Passport A00001109 (Nicaragua) issued 13 Nov 2015 expires 13 Nov 2025; National ID No. 6010302490003J (Nicaragua) (individual) [NICARAGUA].

LOPEZ GOMEZ, Roberto Jose, Calle Real Xalteva, De La Iglesia De Xalteva 75 VRS Al Este, Granada, Nicaragua; DOB 07 Apr 1971; POB Granada, Nicaragua; nationality Nicaragua; Gender Male; National ID No. 2010704710008K (Nicaragua) (individual) [NICARAGUA].

to their Nicaragua sanctions, and the following person:

KOUFFA, Amadou (a.k.a. KOUFFA, Hamadou; a.k.a. KOUFFA, Hamadoun; a.k.a. “BARRY, Amadou”), Mali; DOB 1958; POB Mali; nationality Mali; Gender Male (individual) [SDGT] (Linked To: JAMA’AT NUSRAT AL-ISLAM WAL-MUSLIMIN).

to the counter terrorism program.

And the State Department issued the following press release about the counter-terror designation:

U.S. Department of State Terrorist Designation of Amadou Kouffa

MEDIA NOTE

OFFICE OF THE SPOKESPERSON

NOVEMBER 7, 2019

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The Department of State has designated Amadou Kouffa as a Specially Designated Global Terrorist (SDGT) under Executive Order 13224, which imposes sanctions on foreign persons who have committed, or pose a significant risk of committing, acts of terrorism. Today’s designation seeks to deny Kouffa the resources to plan and carry out terrorist attacks. Among other consequences, all of his property and interests that are in the United States, that hereafter come within the United States, or hereafter come within the possession or control of U.S. persons, have been blocked, and U.S. persons are generally prohibited from engaging in any transactions with him.

Amadou Kouffa is a senior member in Jama’at Nusrat al-Islam wal-Muslimin (JNIM), an al-Qa’ida affiliate active in the Sahel region of Africa, which the Department of State designated as a Foreign Terrorist Organization and SDGT in September 2018. JNIM was formed in March 2017 and is led by Iyad ag Ghali, a designated SDGT.

JNIM has claimed responsibility for numerous attacks and kidnappings since March 2017, killing more than 500 civilians. These include the June 2017 attack at a resort frequented by Westerners outside of Bamako, Mali; several deadly attacks on Malian troops; and the large-scale coordinated attacks in Ouagadougou, Burkina Faso, on March 2, 2018. Earlier this year, Kouffa led an attack against the Malian army in which more than 20 soldiers were killed.

Today’s designation notifies the U.S. public and the international community that Amadou Kouffa has committed, or poses a significant risk of committing, acts of terrorism. Designations of terrorist individuals and groups expose and isolate them, and deny them access to the U.S. financial system. Moreover, designations can assist the law enforcement actions of other U.S. agencies and governments.

A list of State Department-designated FTOs and SDGTs is available here: https://www.state.gov/terrorist-designations-and-state-sponsors-of-terrorism/

Links:

OFAC Notice

State Department Press Release

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November 8, 2019: Oopsie! OFAC fixes a Nicaragua listing…

November 11, 2019, 6:40 am

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On Friday, OFAC corrected a bunch of mistakes in the following Nicaragua sanctions listing:

LOPEZ GOMEZ, Roberto Jose, Calle Real Xalteva, De La Iglesia De Xalteva 75 VRS Al Este, Granada, Nicaragua; DOB 07 Apr 1971; POB Granada, Nicaragua; nationality Nicaragua; Gender Male; National ID No. 2010704710008K (Nicaragua) (individual) [NICARAGUA]. -to- LOPEZ GOMEZ, Roberto Jose, Col. Pereira, CST 2C. S. 2C. O. Casa No. 1341, Managua, Managua, Nicaragua; DOB 22 Apr 1963; POB Madrid, Spain; Gender Male; National ID No. 8882204630000A (Nicaragua) (individual) [NICARAGUA].

Link:

OFAC Notice

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November 18, 2019: A raft of new OFAC counter terrorism designations

November 19, 2019, 6:40 am

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On Monday, OFAC added the following people:

BAYALTUN, Ahmet, Turkey; DOB 1971; citizen Turkey; Gender Male (individual) [SDGT] (Linked To: ISLAMIC STATE OF IRAQ AND THE LEVANT).

BAYALTUN, Ismail (a.k.a. BAYALTUN, Ismail Halil), Dunya Is Mer, Gaziantep, Turkey; No:/A Atlikonak, Sanliurfa 63000, Turkey; DOB 01 Oct 1989; alt. DOB 21 Nov 1980; citizen Turkey; Gender Male; National ID No. C13638980 (Turkey); Identification Number 4386794904 (Turkey) (individual) [SDGT] (Linked To: ISLAMIC STATE OF IRAQ AND THE LEVANT).

KHAN, Sayed Habib Ahmad (a.k.a. KHAN, Syed Habib Ahmad; a.k.a. “HABIB, Sayed”), Kuwait; Arzan Qemat Area, PD 12, Kabul City, Afghanistan; DOB 1970; POB Kunar Province, Afghanistan; nationality Afghanistan; Gender Male; Residency Number 270010174266 (Kuwait) issued 25 Apr 2016 expires 24 Jun 2018 (individual) [SDGT] (Linked To: NEJAAT SOCIAL WELFARE ORGANIZATION).

WAKIL, Rohullah (a.k.a. WAKIL, Haji Sahib Rohullah; a.k.a. “Haji Rohullah”), Afghanistan; DOB 1962; alt. DOB 1963; POB Nangalam, Afghanistan; Gender Male (individual) [SDGT] (Linked To: ISIL KHORASAN).

and entities:

ACL ITHALAT IHRACAT (a.k.a. ACL GSM IMPORT EXPORT; a.k.a. ACL ITHALAT IHRACAT ISMAIL BAYALT; a.k.a. ACL ITHALAT IHRACAT ISMAIL BAYALTUN), No: 96 Dunya Is Merkezi 2 Kat, Sanliurfa, Turkey; Cengiz Topel Mah 2 Dun is Merk, Sanliurfa, Turkey; Yusufpasa Mah Dunya Is Merkeri Ctr, Sanliurfa 63000, Turkey; 96 Earth Business Center, 2nd Floor, Sanliurfa, Turkey [SDGT] (Linked To: BAYALTUN, Ismail).

AL SULTAN MONEY TRANSFER COMPANY (a.k.a. AL SULTAN GOLD & JEWELRY; a.k.a. AL SULTAN GOLD AND JEWELRY; a.k.a. AL SULTAN JEWELRY; a.k.a. AL-SULTAN JEWELRY & GENERAL TRADING CO; a.k.a. AL-SULTAN JEWELRY AND GENERAL TRADING CO; a.k.a. ALSULTAN KUYUMCULUK; a.k.a. ALSULTAN KUYUMCULUK ELEKTRONIK GIDA ITHALAT IHRACAT LIMITED SIRKETI; a.k.a. SULTAN GOLD), Ataturk Mah. Sehit Nusret Cad., No: 17 A/1 Haliliye-Haliliye, Sanliurfa, Turkey [SDGT] (Linked To: ISLAMIC STATE OF IRAQ AND THE LEVANT).

NEJAAT SOCIAL WELFARE ORGANIZATION (a.k.a. NEJAT-E EJTIMAYEE), House Number 1297, Lot Number 2, Sub-District number 2, Narang Bagh Area, Jalalabad, Nangarhar, Afghanistan; Police District 12, Kabul City, Kabul Province, Afghanistan; Jalalabad City, Nangarhar Province, Afghanistan [SDGT] (Linked To: ISIL KHORASAN).

SAHLOUL MONEY EXCHANGE COMPANY (a.k.a. AL-SAHLOUL MONEY EXCHANGE COMPANY; a.k.a. SAHLUL HAWALA OFFICE), Axray, Masseeh Basha, Lalleli Street, Kalvan Centre Building #22, Office #203, Istanbul, Turkey; Mersin, Turkey [SDGT] (Linked To: ISLAMIC STATE OF IRAQ AND THE LEVANT).

TAWASUL COMPANY (a.k.a. AL-TAWASUL COMPANY; a.k.a. TAWASUL FINANCIAL EXCHANGE; a.k.a. TAWASUL HAWALA COMPANY), Harim, Syria [SDGT] (Linked To: ISLAMIC STATE OF IRAQ AND THE LEVANT).

to its counter terrorism sanctions program.

Link:

OFAC Notice

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OFAC publishes updated Venezuela Sanctions Regulations

November 21, 2019, 7:36 am

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Publication of Amended Venezuela Sanctions Regulations

11/21/2019

The Office of Foreign Assets Control (OFAC) is amending the Venezuela Sanctions Regulations, 31 C.F.R. part 591, to incorporate additional Executive orders, add a general license authorizing U.S. Government activities, and add an interpretive provision. This regulatory amendment is currently available for public inspection with the Federal Register and will take effect upon publication in the Federal Register on November 22, 2019.

Links:

OFAC Notice

Amended Venezuela Sanctions Regulations

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New article published on KYC360

November 22, 2019, 6:00 am

≫ Next: November 22, 2019: OFAC adds 1 person to Iran sanctions

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Editors always make your titles too long so that everyone knows what it’s about.

Original title: Hold on a Second(ary)

Final title: Hold on a Second(ary): Rethinking OFAC”s Expanded Sanctions Powers

You can find it here… hope you like it.

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November 22, 2019: OFAC adds 1 person to Iran sanctions

November 25, 2019, 6:20 am

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On Friday, OFAC added the following individual:

AZARI JAHROMI, Mohammad Javad, Iran; DOB 16 Sep 1981; POB Jahrom, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [IRAN] [IRAN-TRA].

to their Iranian sanctions program – specifically, under the Iran Threat Reduction and Syria Human Rights Act of 2012.

Link:

OFAC Notice

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OFAC Enforcement Action takes bite out of Apple

November 26, 2019, 6:45 am

≫ Next: November 26, 2019: CORPORACION PANAMERICANA S.A. added to OFAC Venezuela sanctions

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Apple paid $466,912 for non-egregious, self-reported violations of the Kingpin Act, as opposed to the base penalty amount of $576,434 and the maximum civil monetary penalty of $74,331,860. Turns out they had a developer company in the App Store who was an SDN, and whose account administrator was, too – and Apple’s screening software and procedures were found wanting:

On July 18, 2008, Apple entered into an app development agreement with SIS, a software company located at 19 Spruha, Trzin 1236, Slovenia. On February 24, 2015, OFAC designated SIS and Savo Stjepanovic (“Stjepanovic”), a director and majority owner of SIS, pursuant to the Foreign Narcotics Kingpin Designation Act, 21 U.S.C. §§ 1901-1908, and added them to the SDN List. OFAC’s public announcement of the designation included SIS’s address, registration number, and tax identification number, and further noted that SIS was linked to Stjepanovic. The SDN List provided the following identifying information for SIS:

SIS D.O.O., 19 Spruha, Trzin 1236, Slovenia; Registration ID 5919070 (Slovenia); Tax ID No. SI91729181 (Slovenia) [SDNTK].

OFAC also published a diagram titled “KARNER Steroid Trafficking Network,” which included a photograph of Stjepanovic, SIS, and a SIS logo.

On the same day that OFAC designated SIS and Stjepanovic, Apple, in accordance with its standard compliance procedures, screened the newly designated SDNTKs against its app developer account holder names using its sanctions screening tool. During this screening, Apple failed to identify that SIS, an App Store developer, was added to the SDN List and was therefore blocked. Apple later attributed this failure to its sanctions screening tool’s failure to match the upper case name “SIS DOO” in Apple’s system with the lower case name “SIS d.o.o.” as written on the SDN List. The term “d.o.o.” is a standard corporate suffix in Slovenia identifying a limited liability company. In addition, even though the address for SIS collected by Apple matched the address for SIS identified and published by OFAC, Apple failed to identify SIS as an SDNTK for over two years after the designation.

On the day of designation, Apple was in possession of Stjepanovic’s full name in its records since he was listed as an “account administrator” in its App Store developer account, though he was not listed as a “developer.” At the time, Apple’s compliance process screened individuals identified as “developers,” but did not screen all of the individual users identified in an App Store account against the SDN List. Apple therefore failed to identify Stjepanovic as an SDNTK.

On the day of designation, any property in which SIS or Stjepanovic had an interest became blocked, and any transactions or dealings in such property by Apple, a U.S. person, were prohibited. Nonetheless, Apple continued to host software applications and associated content (“apps”) owned by SIS on the App Store, allowed downloads and sales of the blocked SIS apps, received payments from App Store users downloading the blocked SIS apps, permitted SIS to transfer and sell its apps to two other developers, and remitted funds on a monthly basis to SIS for the sales of the blocked SIS apps.

On or about April 17, 2015 — approximately two months after the designations — Apple facilitated the transfer of a portion of SIS’s apps to a second software company (the “Second Company”). The Second Company was incorporated several days after OFAC’s designation of SIS. Separately, on or about September 14, 2015, SIS entered into an agreement with a third software company (the “Third Company”) and transferred the ownership of SIS’s remaining apps to the Third Company. The owner of the Third Company took over the administration of SIS’s App Store account and replaced SIS’s App Store banking information with his own banking information. These actions were all conducted without personnel oversight or additional screening by Apple.

After enhancing its sanctions screening tool and related processes, Apple identified SIS as a potential SDNTK in February 2017. Apple’s finance team immediately suspended further payments associated with the SIS account, which was being administered by the Third Company, and whose owner was receiving payments from Apple. However, Apple continued to make payments to the Second Company for the blocked SIS apps that had been transferred to the Second Company in April 2015, after OFAC’s designation of SIS as a SDNTK.

Apple made 47 payments associated with the blocked apps, including payments directly to SIS, during the period of time that SIS was listed on the SDN List. In total, over 54 months, Apple collected $1,152,868 from customers who downloaded SIS apps.

Here are the aggravating factors, according to OFAC:

(1) Based on the number of Apparent Violations, the length of time over which the Apparent Violations occurred, and the multiple points of failure within the company’s sanctions compliance program, policies, and procedures, the conduct demonstrated reckless disregard for U.S. sanctions requirements;

(2) Apple’s payments to SIS and for the blocked apps conferred significant economic benefit to SIS and its owner, as Apple’s App Store appears to have been the main business for SIS around the time it was designated; and

(3) Apple is a large and sophisticated organization operating globally with experience and expertise in international transactions.

OFAC found the following to be an aggravating factor with respect to three Apparent Violations that occurred after Apple identified SIS as an SDNTK in February 2017:

(4) Apple failed to take corrective actions in a timely manner after identifying SIS as an SDNTK, and continued to make payments for the download of blocked apps for multiple months.

And the mitigating factors:

(1) The volume and total amount of payments underlying the Apparent Violations was not significant compared to the total volume of transactions undertaken by Apple on an annual basis;

(2) Apple has not received a penalty notice or Finding of Violation from OFAC in the five years preceding the date of the transaction giving rise to the Apparent Violations; and

(3) Apple responded to numerous requests for information in a prompt manner

And Apple’s remediation:

• Increased the role of the Global Export and Sanctions Compliance Senior Manager in the escalation and review process;

• Reconfigured the primary sanctions screening tool to fully capture spelling and capitalization variations and to account for country-specific business suffixes, and implemented an annual review of the tool’s logic and configuration;

• Expanded sanctions screening to include not only app developers, but also their designated payment beneficiaries and associated banks;

• Updated the instructions for employees to review potential SDN List matches flagged by the primary sanctions screening tool; and

• Implemented mandatory training for all employees on export and sanctions regulations.

And the lesson to be learned:

This enforcement action highlights the benefit of comprehensive SDN List screening that utilizes all of the information on the SDN List. Companies should consider OFAC screening and compliance measures that exploit names, addresses, and other identifying information on the SDN List. Compliance measures should also anticipate potential vulnerabilities in a company’s compliance program that could allow sanctions evasion and circumvention, and should include preventative measures that alert and react to sanctions evasion warning signs, such as business and employment connections between individuals and entities.

Link:

OFAC Enforcement Information

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November 26, 2019: CORPORACION PANAMERICANA S.A. added to OFAC Venezuela sanctions

November 27, 2019, 6:15 am

≫ Next: November 27, 2019: OFAC updates Iran FAQs

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On Tuesday, OFAC added the following Cuban firm:

CORPORACION PANAMERICANA S.A., Ave. 7MA. No. 6209 E/ 62 Y 66, Playa, Miramar, Havana, Cuba [VENEZUELA-EO13850] (Linked To: CUBAMETALES).

to its Venezuela sanctions program.

Link:

OFAC Notice

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November 27, 2019: OFAC updates Iran FAQs

December 2, 2019, 6:55 am

≫ Next: December 3, 2019: OFAC adds vessels to Venezuela sanctions

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Last Wednesday, OFAC updated Frequently Asked Question (FAQ) #303:

303. Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under IFCA’s section 1246(a)(1)?

A number of insurance activities are subject to sanctions under IFCA, including knowingly providing insurance, reinsurance, or underwriting services to or for Iranian persons on the SDN List to or for any person designated in connection with Iran’s support for international terrorism or WMD proliferation, or for activities with respect to Iran for which sanctions have been imposed (e.g., knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran). However, the provision of insurance, reinsurance, or underwriting services to non-Iranian persons on the SDN List is generally not sanctionable under section 1246(a)(1) of IFCA if the provision of insurance, reinsurance or underwriting services is not to or for an Iranian person on the SDN List, to or for any person designated in connection with Iran’s support for international terrorism or WMD proliferation, or for any activity with respect to Iran for which sanctions have been imposed. [11-27-2019]

and FAQ 804:

804. Do sanctions on COSCO Shipping Tanker (Dalian) Co. and COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. apply to their corporate parent and affiliates?

COSCO Shipping Tanker (Dalian) Co. and COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. were determined by the Secretary of State on September 25, 2019, to meet the criteria for the imposition of sanctions under Executive Order (E.O.) 13846, and the Secretary of State imposed certain sanctions, including blocking, on these entities. The blocking sanctions apply only to these listed entities and any entities in which they own, individually or in the aggregate, a 50 percent or greater interest. Sanctions do not apply to these entities’ ultimate parent, COSCO Shipping Corporation Ltd. (COSCO). Similarly, sanctions do not apply to COSCO’s other subsidiaries or affiliates (e.g., COSCO Shipping Holdings), provided that such entities are not owned 50 percent or more in the aggregate by one or more blocked persons. U.S. persons, therefore, are not prohibited from dealing with COSCO, its non-blocked subsidiaries, or non-blocked affiliates to the extent the proposed dealings do not involve any blocked person, or any other activities prohibited pursuant to any OFAC sanctions authorities.

In addition, on October 24, 2019, OFAC issued General License K that authorizes through its expiration date all transactions and activities prohibited pursuant to section 5 of E.O. 13846 that are ordinarily incident and necessary to the maintenance or wind down of transactions involving COSCO Shipping Tanker (Dalian) Co., subject to certain conditions specified in the license and described in FAQ 806.

With respect to transactions involving non U.S. persons outside of U.S. jurisdiction, please see FAQ 805. [11-27-2019]

and added three new ones:

805. Are non-U.S. persons exposed to sanctions for providing goods or services to, or engaging in other transactions with, a non-Iranian person sanctioned under section 3 of E.O. 13846?

No, non-U.S. persons are generally not exposed to sanctions for providing goods or services to, or engaging in other transactions with, a non-Iranian person sanctioned under section 3 of E.O. 13846.

However, please note that non-U.S. persons should ensure that the provision of goods or services to, or other transactions with such non-Iranian persons do not involve: (1) prohibited transactions by U.S. persons (including U.S. financial institutions) or U.S.-owned or -controlled foreign entities, unless the transaction is exempt from regulation, or authorized by OFAC; (2) the knowing provision of significant support to an Iranian person on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List); or (3) the knowing facilitation of a significant transaction for a person on the SDN List that has been designated in connection with Iran’s support for international terrorism or proliferation of weapons of mass destruction, including designated Iranian financial institutions or the Islamic Revolutionary Guard Corps (IRGC), or other activity for which sanctions have been imposed with respect to Iran (e.g., knowingly engaging in a significant transaction for the purchase of petroleum from Iran).

For information about persons sanctioned by State Department pursuant to Section 3 of E.O. 13846, please see the relevant State press statement or Federal Register Notice. [11-27-2019]

806. What types of activities are considered “maintenance” as the term is used in General License K?

As a general matter, the authorization for “maintenance” in General License K includes all transactions ordinarily incident to the continuity of operations by U.S. persons involving COSCO Shipping Tanker (Dalian) Co., Ltd. or any entity owned, directly or indirectly, 50 percent or more by COSCO Shipping Tanker (Dalian) Co., Ltd., other than COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. or any entity owned, directly or indirectly, 50 percent or more by COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. (hereinafter, “General License K Covered Entities”). Additionally, for the purposes of General License K, the authorization for “maintenance” generally includes all transactions and activities ordinarily incident to performing under a contract or agreement in effect prior to September 25, 2019, provided that the level of performance is consistent with the terms of the general license and consistent with past practices that existed between the party and the General License K Covered Entities prior to September 25, 2019. Notwithstanding the absence of a contract or agreement in effect prior to September 25, 2019, the authorization for “maintenance” also generally includes all transactions and activities ordinarily incident to obtaining goods or services from, or providing goods or services to, General License K Covered Entities in a manner consistent with the terms of the general license and consistent with past practices that existed between the party, or any intermediary party, and the General License K Covered Entities prior to September 25, 2019. OFAC will consider the transaction history between the party, or any intermediary party, and the General License K Covered Entities prior to September 25, 2019 in assessing whether activity is consistent with past practices. The authorization for “maintenance” also generally includes authorization to enter into contingent contracts for transactions and activities consistent with the above, extending beyond the current expiration of General License K where any performance after the expiration of the general license is contingent on such performance either not being prohibited or being authorized by OFAC.

For example, transactions and activities authorized by General License K could include issuing or accepting purchase orders (including for sales of fuel to General License K Entities) and making or receiving shipments (including undertaking new charters or voyages) that were initiated after September 25, 2019 involving General License K Entities, if such activity is ordinarily incident and necessary to contracts in effect prior to September 25, 2019 (provided the purchase and shipment amounts are consistent with past practices, as demonstrated by transaction history). Similarly, transactions and activities that are not within the framework of a preexisting agreement may be considered “maintenance” if such activity is consistent with the transaction history between the person and General License K Entities prior to September 25, 2019. Conversely, General License K would not authorize purchase orders and shipments involving the General License K Entities where there was no preexisting relationship between a person and a blocked entity or where the contemplated activity exceeds past practices that existed between the party and the General License K Entities prior to September 25, 2019 as demonstrated by transaction history. Stockpiling inventory, for example, would not be authorized unless transaction history indicates that the scope and extent of maintaining inventory is consistent with past practice. [11-27-2019]

807. Can U.S. financial institutions process transactions involving COSCO Shipping Tanker (Dalian) Co., Ltd. under Iran General License K if the U.S. financial institution is the only U.S. person involved in the transaction?

Yes, provided the transaction is ordinarily incident and necessary to the maintenance or wind down of transactions involving, directly or indirectly, COSCO Shipping Tanker (Dalian) Co., Ltd., or any entity owned, directly or indirectly, 50 percent or more by COSCO Shipping Tanker (Dalian) Co., Ltd., including any transaction or dealing in property or interests in property of the foregoing, subject to the conditions and expiration dates noted in Iran General License K. However, please note that Iran General License K does not authorize any transactions involving COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. or any entity owned, directly or indirectly, 50 percent or more by COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co.

Please note that absent knowledge or a reason to know that the transaction is not authorized by Iran General License K, OFAC would not expect the intermediary U.S. financial institution to conduct additional due diligence beyond the information collected in the ordinary course of processing such transactions, and accordingly, in the event of a potential violation, OFAC would consider the totality of the facts and circumstances in determining the appropriate administrative enforcement response, if any.

Please see FAQ 116 for additional guidance on due diligence for U.S. financial institutions serving as intermediaries within a transaction. [11-27-2019]

Links:

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December 3, 2019: OFAC adds vessels to Venezuela sanctions

December 4, 2019, 6:10 am

≫ Next: OFAC designates Evil Corp under cyber sanctions, and removes a terrorist

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On Tuesday, OFAC added:

ICARO Crude Oil Tanker Panama flag; Vessel Registration Identification IMO 9038842 (vessel) [VENEZUELA-EO13884] (Linked To: PETROLEOS DE VENEZUELA, S.A.).

LUISA CACERES DE ARISMENDI Products Tanker Venezuela flag; Vessel Registration Identification IMO 9117478 (vessel) [VENEZUELA-EO13884] (Linked To: PETROLEOS DE VENEZUELA, S.A.).

MANUELA SAENZ Products Tanker Venezuela flag; Vessel Registration Identification IMO 9117492 (vessel) [VENEZUELA-EO13884] (Linked To: PETROLEOS DE VENEZUELA, S.A.).

PARAMACONI Crude Oil Tanker Venezuela flag; Vessel Registration Identification IMO 9543512 (vessel) [VENEZUELA-EO13884] (Linked To: PETROLEOS DE VENEZUELA, S.A.).

TEREPAIMA Crude Oil Tanker Venezuela flag; Vessel Registration Identification IMO 9552496 (vessel) [VENEZUELA-EO13884] (Linked To: PETROLEOS DE VENEZUELA, S.A.).

YARE Crude Oil Tanker Venezuela flag; Vessel Registration Identification IMO 9543500 (vessel) [VENEZUELA-EO13884] (Linked To: PETROLEOS DE VENEZUELA, S.A.).

and modified:

NEDAS Crude Oil Tanker Greece flag; Vessel Registration Identification IMO 9289166 (vessel) [VENEZUELA-EO13850] (Linked To: JENNIFER NAVIGATION LIMITED). -to- ESPERANZA (f.k.a. NEDAS) Crude Oil Tanker Cuba flag; Former Vessel Flag Greece; Vessel Registration Identification IMO 9289166 (vessel) [VENEZUELA-EO13850] (Linked To: CAROIL TRANSPORT MARINE LTD).

vessels on the SDN List under the Venezuela sanctions program.

And the State Department issued the following press release:

The United States Takes Action Against the Movement of Venezuelan Oil to Cuba

PRESS STATEMENT

MICHAEL R. POMPEO, SECRETARY OF STATE

DECEMBER 3, 2019

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On December 3, the United States identified six PDVSA-owned vessels, pursuant to E.O. 13884 or 13850, being used by the former Maduro regime to ship oil to Cuba. In addition, the Esperanza was identified as the new name for the vessel previously named the Nedas, which was blocked on April 12, 2019. These actions block the efforts by the Cuban and former Maduro regimes to evade sanctions that are intended to prevent the theft of Venezuela’s natural resources for corrupt purposes.

While the Venezuelan people continue to take to the streets to demand basic services and a return to freedom and prosperity, Maduro chooses to ship a vital natural resource to Cuba in exchange for Cuban security and intelligence services that preserve his influence in Venezuela. Cuba continues to prop up Nicolas Maduro, subverting the Venezuelan people’s right to self-determination and undermining Venezuelan institutions.

The United States will continue to promote accountability for Cuba’s actions in Venezuela. The United States is steadfast in its support for the people of Venezuela, interim President Juan Guaido, and the democratically elected National Assembly.

Links:

OFAC Notice

State Department Press Release

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OFAC designates Evil Corp under cyber sanctions, and removes a terrorist

December 5, 2019, 8:41 am

≫ Next: December 6, 2019: OFAC designates Iraqis under Global Magnitsky sanctions

≪ Previous: December 3, 2019: OFAC adds vessels to Venezuela sanctions

Earlier today, OFAC added the following persons:

ALVARES, Carlos, Moscow, Russia; DOB 18 May 1971; POB Spain; Gender Male; National ID No. AV176942 (Spain) (individual) [CYBER2] (Linked To: EVIL CORP).

BASHLIKOV, Aleksei, Moscow, Russia; DOB 18 Mar 1988; POB Russia; Gender Male; Passport 4509592875 (Russia) (individual) [CYBER2] (Linked To: EVIL CORP).

BURKHONOVA, Gulsara, Moscow, Russia; DOB 06 Apr 1977; POB Russia; alt. POB Tajikistan; Gender Female; Passport 9707561379 (Russia) (individual) [CYBER2] (Linked To: EVIL CORP).

GUBERMAN, David, Moscow, Russia; DOB 01 Mar 1971; POB Ukraine; Gender Male; National ID No. 7201105 (Israel) (individual) [CYBER2] (Linked To: EVIL CORP).

GUSEV, Denis Igorevich (Cyrillic: ГУСЕВ, ДЕНИС ИГОРЕВИЧ) (a.k.a. GOTMAN, David; a.k.a. POMOJAC, Marin), Moscow, Russia; DOB 10 Jun 1986; alt. DOB 08 Jul 1977; alt. DOB 07 Oct 1987; POB Moscow, Russia; alt. POB Ceadir-Lunga, Moldova; citizen Russia; Gender Male; Passport 717386212 (Russia); alt. Passport A1167292 (Moldova); alt. Passport 1213007 (Israel) (individual) [CYBER2] (Linked To: EVIL CORP).

MANIDIS, Georgios, Moscow, Russia; DOB 23 Aug 1971; Gender Male; National ID No. AV2752462 (Greece) (individual) [CYBER2] (Linked To: EVIL CORP).

PLOTNITSKIY, Andrey (a.k.a. KOVALSKIY, Andrey Vechislavovich; a.k.a. STREL, Andrey), Moscow, Russia; DOB 25 Jul 1989; Gender Male (individual) [CYBER2] (Linked To: EVIL CORP).

SAFAROV, Azamat, Moscow, Russia; DOB 26 Mar 1990; POB Uzbekistan; Gender Male; National ID No. CE2236830 (Uzbekistan) (individual) [CYBER2] (Linked To: EVIL CORP).

SHEVCHUK, Tatiana, Moscow, Russia; DOB 08 Jan 1970; Gender Female; National ID No. BB299742 (Ukraine) (individual) [CYBER2] (Linked To: EVIL CORP).

SLOBODSKOY, Dmitriy Alekseyevich, Russia; DOB 28 Jul 1988; Gender Male; Passport 721007353 (Russia) (individual) [CYBER2] (Linked To: EVIL CORP).

SLOBODSKOY, Kirill Alekseyevich, Moscow, Russia; DOB 26 Feb 1987; POB Moscow, Russia; nationality Russia; Gender Male; Passport 721025114 (Russia); National ID No. 4508818947 (Russia) (individual) [CYBER2] (Linked To: EVIL CORP).

SMIRNOV, Dmitriy Konstantinovich, Moscow, Russia; DOB 10 Nov 1987; citizen Russia; Gender Male (individual) [CYBER2] (Linked To: EVIL CORP).

TUCHKOV, Ivan Dmitriyevich, Russia; DOB 27 Nov 1986; POB Moscow, Russia; Gender Male; Passport 45092006504 (Russia); alt. Passport 753931329 (Russia); VisaNumberID 525867504 (France) (individual) [CYBER2] (Linked To: EVIL CORP).

TURASHEV, Igor Olegovich (a.k.a. “ENKI”; a.k.a. “NINTUTU”), Russia; DOB 15 Jun 1981; Gender Male (individual) [CYBER2] (Linked To: EVIL CORP).

YAKUBETS, Artem Viktorovich, Moscow, Russia; DOB 17 Jan 1986; POB Polonnoye, Khmelnitskaya Oblast, Ukraine; citizen Russia; Gender Male (individual) [CYBER2] (Linked To: EVIL CORP).

YAKUBETS, Maksim Viktorovich (a.k.a. “AQUA”), Moscow, Russia; DOB 20 May 1987; POB Polonnoye, Khmelnitskaya Oblast, Ukraine; citizen Russia; Gender Male; Passport 4509135586 (Russia) (individual) [CYBER2] (Linked To: EVIL CORP; Linked To: FEDERAL SECURITY SERVICE).

ZAMULKO, Ruslan, Moscow, Russia; DOB 25 Jun 1970; POB Ukraine; Gender Male; National ID No. HB698865 (Ukraine) (individual) [CYBER2] (Linked To: EVIL CORP).

and entities:

BIZNES-STOLITSA, OOO (Cyrillic: ООО БИЗНЕС-СТОЛИЦА) (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU BIZNES-STOLITSA), d. 14 korp. 1 pom. Khll/kom. 1, ul., Sokolovo-Meshcherskaya Moscow, Moscow 125466, Russia; D-U-N-S Number 50-722-4994; Tax ID No. 7733904024 (Russia); Government Gazette Number 40335667 (Russia); Registration Number 5147746417682 (Russia) [CYBER2] (Linked To: GUSEV, Denis Igorevich).

EVIL CORP (a.k.a. DRIDEX GANG), Moscow, Russia; Moldova [CYBER2].

OPTIMA, OOO (Cyrillic: ООО ОПТИМА) (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU OPTIMA), d. 2 korp. 2 pom. 1, ul., Kominterna Moscow, Moscow 129344, Russia; D-U-N-S Number 50-579-8144; Tax ID No. 7716740680(Russia); Government Gazette Number 17325717 (Russia); Registration Number 1137746232260 (Russia) [CYBER2] (Linked To: GUSEV, Denis Igorevich).

TREID-INVEST, OOO (Cyrillic: ООО ТРЕЙД-ИНВЕСТ) (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU TREID-INVEST), 11/2, ul., Sadovaya-Chernogryazskaya Moscow, Moscow 105064, Russia; D-U-N-S Number 50-722-5114; Tax ID No. 7701416320 (Russia); Government Gazette Number 40214946 (Russia); Registration Number 5147746418782 (Russia) [CYBER2] (Linked To: GUSEV, Denis Igorevich).

TSAO, OOO (Cyrillic: ООО ЦАО) (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU TSENTR AVTOOBSLUZHIVANIYA), 9, per., Omski Kurgan, Kurganskaya Oblast 640000, Russia; D-U-N-S Number 68-215-4722; Tax ID No. 4501122896 (Russia); Government Gazette Number 78739479 (Russia); Registration Number 1064501172394 (Russia) [CYBER2] (Linked To: GUSEV, Denis Igorevich).

VERTIKAL, OOO (Cyrillic: ООО ВЕРТИКАЛЬ) (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU VERTIKAL), d. 102/1, ul. Beregovaya Kogalym, Khanty-Mansiski, Avtonomny Okrug – Yugra Okr. 628482, Russia; D-U-N-S Number 50-630-4726; Tax ID No. 8608056026 (Russia); Government Gazette Number 26149774 (Russia); Registration Number 1138608000189 (Russia) [CYBER2] (Linked To: GUSEV, Denis Igorevich).

YUNIKOM, OOO (Cyrillic: ООО ЮНИКОМ) (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU YUNIKOM), d. 18, ul. Tsentralnaya Kogalym, Khanty-Mansiski, Avtonomny Okrug – Yugra Okr. 628483, Russia; D-U-N-S Number 68-321-9795; Tax ID No. 8608052180 (Russia); Government Gazette Number 97396163 (Russia); Registration Number 1068608008204 (Russia) [CYBER2] (Linked To: GUSEV, Denis Igorevich).

to the SDN List under its cyber-related sanctions program.

Additionally, it removed the following listings under the counter terrorism sanctions program:

AMHAZ, Issam Mohamad (a.k.a. AMHAZ, ‘Isam; a.k.a. AMHAZ, Issam Mohamed), Ghadir, 5th Floor, Safarat, Bir Hassan, Jenah, Lebanon; Issam Mohamad Amhaz Property, Ambassades (Safarate), Bir Hassan Area , Ghobeiri, Baabda, Lebanon; DOB 04 Mar 1967; POB Baalbek, Lebanon; nationality Lebanon; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Passport RL0000199 (Lebanon); Identification Number 61 Nabha; Chairman, Stars Group Holding; General Manager, Teleserveplus (individual) [SDGT].

AMHAZ, Issam Mohamed (a.k.a. AMHAZ, ‘Isam; a.k.a. AMHAZ, Issam Mohamad), Ghadir, 5th Floor, Safarat, Bir Hassan, Jenah, Lebanon; Issam Mohamad Amhaz Property, Ambassades (Safarate), Bir Hassan Area , Ghobeiri, Baabda, Lebanon; DOB 04 Mar 1967; POB Baalbek, Lebanon; nationality Lebanon; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Passport RL0000199 (Lebanon); Identification Number 61 Nabha; Chairman, Stars Group Holding; General Manager, Teleserveplus (individual) [SDGT].

AMHAZ, ‘Isam (a.k.a. AMHAZ, Issam Mohamad; a.k.a. AMHAZ, Issam Mohamed), Ghadir, 5th Floor, Safarat, Bir Hassan, Jenah, Lebanon; Issam Mohamad Amhaz Property, Ambassades (Safarate), Bir Hassan Area , Ghobeiri, Baabda, Lebanon; DOB 04 Mar 1967; POB Baalbek, Lebanon; nationality Lebanon; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Passport RL0000199 (Lebanon); Identification Number 61 Nabha; Chairman, Stars Group Holding; General Manager, Teleserveplus (individual) [SDGT].

And the Treasury Department issued the following press release:

PRESS RELEASES

Treasury Sanctions Evil Corp, the Russia-Based Cybercriminal Group Behind Dridex Malware

December 5, 2019

Washington – Today the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) took action against Evil Corp, the Russia-based cybercriminal organization responsible for the development and distribution of the Dridex malware. Evil Corp has used the Dridex malware to infect computers and harvest login credentials from hundreds of banks and financial institutions in over 40 countries, causing more than $100 million in theft. This malicious software has caused millions of dollars of damage to U.S. and international financial institutions and their customers. Concurrent with OFAC’s action, the Department of Justice charged two of Evil Corp’s members with criminal violations, and the Department of State announced a reward for information up to $5 million leading to the capture or conviction of Evil Corp’s leader. These U.S. actions were carried out in close coordination with the United Kingdom’s National Crime Agency (NCA). Additionally, based on information obtained by the Treasury Department’s Financial Crimes Enforcement Network (FinCEN), the Treasury Department’s Office of Cybersecurity and Critical Infrastructure Protection (OCCIP) released previously unreported indicators of compromise associated with the Dridex malware and its use against the financial services sector.

“Treasury is sanctioning Evil Corp as part of a sweeping action against one of the world’s most prolific cybercriminal organizations. This coordinated action is intended to disrupt the massive phishing campaigns orchestrated by this Russian-based hacker group,” said Steven T. Mnuchin, Secretary of the Treasury. “OFAC’s action is part of a multiyear effort with key NATO allies, including the United Kingdom. Our goal is to shut down Evil Corp, deter the distribution of Dridex, target the “money mule” network used to transfer stolen funds, and ultimately to protect our citizens from the group’s criminal activities.”

Worldwide, cybercrime results in losses that total in the billions of dollars, while in the United States, financial institutions and other businesses remain prime targets for cybercriminals. Today’s action clarifies that, in addition to his involvement in financially motivated cybercrime, the group’s leader, Maksim Yakubets, also provides direct assistance to the Russian government’s malicious cyber efforts, highlighting the Russian government’s enlistment of cybercriminals for its own malicious purposes. Maksim Yakubets is not the first cybercriminal to be tied to the Russian government. In 2017, the Department of Justice indicted two Russian Federal Security Service (FSB) officers and their criminal conspirators for compromising millions of Yahoo email accounts. The United States Government will not tolerate this type of activity by another government or its proxies and will continue to hold all responsible parties accountable.

Today’s designations and indictments were issued in furtherance of previous international actions targeting Evil Corp in an effort to further disrupt and degrade the group’s ability to operate. In October 2015, the Department of Justice indicted Andrey Ghinkul for spreading the Dridex malware. At that same time, the Federal Bureau of Investigation and the NCA disrupted the global infrastructure utilized at the time by Evil Corp. Over the past several years, the NCA and the United Kingdom’s Metropolitan Police Service have arrested multiple individuals who enabled the activities of Evil Corp, including laundering stolen proceeds acquired through the Dridex malware.

As a result of today’s designations, all property and interests in property of these persons subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them. Additionally, any entities 50 percent or more owned by one or more designated persons are also blocked. Foreign persons may be subject to secondary sanctions for knowingly facilitating a significant transaction or transactions with these designated persons.

DESIGNATION TARGETS

Today’s action targets 17 individuals and seven entities to include Evil Corp, its core cyber operators, multiple businesses associated with a group member, and financial facilitators utilized by the group. OFAC designated these persons pursuant to Executive Order (E.O.) 13694, as amended, which targets malicious cyber-enabled actors around the world, and as codified by the Countering America’s Adversaries Through Sanctions Act.

Evil Corp is the Russia-based cybercriminal organization responsible for the development and distribution of the Dridex malware. The Dridex malware is a multifunctional malware package that is designed to automate the theft of confidential information, to include online banking credentials from infected computers. Dridex is traditionally spread through massive phishing email campaigns that seek to entice victims to click on malicious links or attachments embedded within the emails. Once a system is infected, Evil Corp uses compromised credentials to fraudulently transfer funds from victims’ bank accounts to those of accounts controlled by the group. As of 2016, Evil Corp had harvested banking credentials from customers at approximately 300 banks and financial institutions in over 40 countries, making the group one of the main financial threats faced by businesses. In particular, Evil Corp heavily targets financial services sector organizations located in the United States and the United Kingdom. Through their use of the Dridex malware, Evil Corp has illicitly earned at least $100 million, though it is likely that the total of their illicit proceeds is significantly higher. As a result of this activity, Evil Corp is being designated pursuant to E.O. 13694, as amended, for engaging in cyber-enabled activities that have the effect of causing a significant misappropriation of funds or economic resources for private financial gain.

Evil Corp operates as a business run by a group of individuals based in Moscow, Russia, who have years of experience and well-developed, trusted relationships with each other. Maksim Yakubets (Yakubets) serves as Evil Corp’s leader and is responsible for managing and supervising the group’s malicious cyber activities. For example, as of 2017, Yakubets supervised Evil Corp actors who were attempting to target U.S. companies. As of 2015, Yakubets maintained control of the Dridex malware and was in direct communication with Andrey Ghinkul prior to the unsealing of his indictment. As a result, Yakubets is being designated pursuant to E.O. 13694, as amended, for having acted for or on behalf of and for providing material assistance to Evil Corp. Prior to serving in this leadership role for Evil Corp, Yakubets was also directly associated with Evgeniy Bogachev, a previously designated Russian cybercriminal responsible for the distribution of the Zeus, Jabber Zeus, and GameOver Zeus malware schemes. In particular, Yakubets was responsible for recruiting and managing a network of individuals responsible for facilitating the movement of money illicitly gained through the efforts spearheaded by Evgeniy Bogachev. Yakubets is the subject of an indictment and criminal complaint unsealed today by the Department of Justice, while the Department of State announced a $5 million reward for information leading to the capture of Yakubets.

In addition to his leadership role within Evil Corp, Yakubets has also provided direct assistance to the Russian government. As of 2017, Yakubets was working for the Russian FSB, one of Russia’s leading intelligence organizations that was previously sanctioned pursuant to E.O. 13694, as amended, on December 28, 2016. As of April 2018, Yakubets was in the process of obtaining a license to work with Russian classified information from the FSB. As a result, Yakubets is also being designated pursuant to E.O. 13694, as amended, for providing material assistance to the FSB. Additionally, as of 2017, Yakubets was tasked to work on projects for the Russian state, to include acquiring confidential documents through cyber-enabled means and conducting cyber-enabled operations on its behalf.

Another key Evil Corp figure targeted today is Igor Turashev (Turashev). As of 2017, Turashev was involved in helping Evil Corp exploit victims’ networks. As of 2015, Turashev served as an administrator for Yakubets and had control over the Dridex malware. As a result, Turashev is being designated pursuant to E.O. 13694, as amended, for having acted for or on behalf of and for providing material assistance to Evil Corp. Turashev is also the subject of an indictment unsealed today by the Department of Justice.

Denis Gusev (Gusev), a senior member of Evil Corp, is also being designated today for his active role in furthering Evil Corp’s activities. As of 2017, Gusev was involved in helping Evil Corp move to a new office location and as of 2018, Gusev served as a financial facilitator for Evil Corp and its members. As a result, Gusev is being designated pursuant to E.O. 13694, as amended, for having acted for or on behalf of and for providing material assistance to Evil Corp.

Gusev also serves as the General Director for six Russia-based businesses. These entities include Biznes-Stolitsa, OOO, Optima, OOO, Treid-Invest, OOO, TSAO, OOO, Vertikal, OOO, and Yunikom, OOO. As a result, these entities are being designated pursuant to E.O. 13694, as amended, for being owned or controlled by Gusev.

In addition to Yakubets, Turashev, and Gusev, Evil Corp relies upon a cadre of core individuals to carry out critical logistical, technical, and financial functions such as managing the Dridex malware, supervising the operators seeking to target new victims, and laundering the proceeds derived from the group’s activities. These additional core members of the group include Dmitriy Smirnov, Artem Yakubets, Ivan Tuchkov, Andrey Plotnitskiy, Dmitriy Slobodskoy, and Kirill Slobodskoy. As a result, these six individuals are being designated pursuant to E.O. 13694, as amended, for having acted for or on behalf of and for providing material assistance to Evil Corp.

To transfer the proceeds gained through their use of the Dridex malware, Evil Corp relies upon a network of money mules who are involved in transferring stolen funds obtained from victims’ bank accounts to accounts controlled by members of Evil Corp. Previously, the NCA arrested multiple individuals in the United Kingdom suspected of laundering the criminal profits of cybercrime schemes, including those perpetrated by Evil Corp, through hundreds of accounts at various banks in the United Kingdom. Today, OFAC is designating eight Moscow-based individuals who have served as financial facilitators for Evil Corp. These individuals include Aleksei Bashlikov, Ruslan Zamulko, David Guberman, Carlos Alvares, Georgios Manidis, Tatiana Shevchuk, Azamat Safarov, and Gulsara Burkhonova. As a result, these eight individuals are being designated pursuant to E.O. 13694, as amended, for providing financial and material assistance to Evil Corp.

And FinCEN and the Office of Cybersecurity and Critical Infrastructure Protection (OCCIP) issued an alert about the Dridex malware.

Links:

OFAC Notice

Treasury Press Release

FinCEN/OCCIP Dridex Malware Alert

↧

December 6, 2019: OFAC designates Iraqis under Global Magnitsky sanctions

December 9, 2019, 6:00 am

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On Friday, OFAC added the following persons:

AL-ISSAWI, Khamis Farhan Al-Khanjar (a.k.a. ALESSAWI, Khamis F Ali; a.k.a. ALI, Khamees Farhan Ali; a.k.a. ALI, Khames Farhan Ali; a.k.a. AL-KHANJAR, Khamis), Jordan; Iraq; DOB 1965; alt. DOB 08 Sep 1968; alt. DOB 08 Sep 1965; POB Fallujah, Iraq; nationality Iraq; Gender Male; Passport D1022354 (Iraq) expires 21 May 2023 (individual) [GLOMAG].

AL-KHAZALI, Laith (a.k.a. ALAZIREG, Layth Hadi Sayyid), Iraq; DOB 14 Oct 1975; nationality Iraq; Gender Male; Passport A10537439 (Iraq) expires 16 Oct 2023 (individual) [GLOMAG].

AL-KHAZALI, Qais (a.k.a. ALAZEREJ, Qays Hadi Sayyid; a.k.a. AL-KHAZALI, Qais Hadi Sayed Hasan), Iraq; DOB 20 Jun 1974; alt. DOB 1974; POB Baghdad, Iraq; nationality Iraq; Gender Male (individual) [GLOMAG].

AL-LAMI, Hussein Falah (a.k.a. AL-LAMI, Abu Zainab; a.k.a. AZIZ, Hussein Faleh), Iraq; DOB 20 Jun 1969; POB Baghdad, Iraq; nationality Iraq; Gender Male (individual) [GLOMAG].

under its Global Magnitsky human rights abuses and corruption sanctions.

The State Department both issued a press release:

On Sanctioning Those Involved in Killing Protestors and Corruption in Iraq

PRESS STATEMENT

MICHAEL R. POMPEO, SECRETARY OF STATE

DECEMBER 6, 2019

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The United States recently expressed its commitment to using its legal authorities to sanction corrupt individuals stealing the Iraqi people’s public wealth and killing and wounding peaceful protesters. Today, we are honoring that pledge by sanctioning four Iraqis implicated in serious human rights abuses and corruption. The Department of Treasury’s Office of Foreign Assets Control (OFAC) designated Iranian-backed militia leaders Qais al-Khazali, Laith al-Khazali, and Husayn Falih ‘Aziz al-Lami, pursuant to Executive Order (E.O.) 13818, for their involvement in serious human rights abuses in Iraq. Additionally, OFAC designated Iraqi politician Khamis Farhan al-Khanjar al-Issawi for bribing government officials and for widespread corruption at the expense of the Iraqi people.

The Iraqi people want their country back. They are calling for genuine reform and accountability and for trustworthy leaders who will put Iraq’s national interests first. Those demands deserve to be addressed without resort to violence or suppression. Human rights abuses and corruption undermine the values that are at the foundation of stable, secure, and functioning societies.

As the world prepares to recognize International Anticorruption Day on December 9 and International Human Rights Day on December 10, the United States is doing its part to advance those very same values and to hold to account those who would undermine them through human rights abuses or acts of corruption.

and held a briefing:

Assistant Secretary for Near Eastern Affairs David Schenker On Iraqi Global Magnitsky Designations

SPECIAL BRIEFING

DAVID SCHENKER, ASSISTANT SECRETARY
BUREAU OF NEAR EASTERN AFFAIRS

PRESS BRIEFING ROOM

WASHINGTON, D.C.

DECEMBER 6, 2019

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MS ORTAGUS: Thank you for joining us for this important briefing. With us today is Assistant Secretary of State for Near Eastern Affairs David Schenker. He’ll be addressing the protests in Iraq and announcing the designation of individuals under the Global Magnitsky Act. Assistant Secretary Schenker will begin with some opening remarks, and then we will take a few questions.

David.

ASSISTANT SECRETARY SCHENKER: Thanks, Morgan. Good afternoon. Today the United States is sanctioning three Iraqis for their involvement in the brutal crackdown on peaceful protesters in Iraq, and a fourth for corruption and bribery.

Treasury designated Qais al-Khazali, Laith al-Khazali, Husayn Falih ‘Aziz al-Lami, pursuant to Executive Order 13818 for their involvement in serious human rights abuses in Iraq. Additionally, OFAC designated politician Khamis Farhan al-Khanjar al-Issawi for bribing government officials and engaging in widespread corruption at the expense of the Iraqi people.

According to the UN, over 400 Iraqis have been killed while protesting for better governance and a brighter future. For several months, the Iraqi people have led a patriotic quest for genuine reform and transparency in government. They have gone to the streets to raise their voices for a just government with leaders who will put Iraq’s national interests first.

Frankly, without that commitment from Iraq’s political leaders, it makes little difference who they designate as prime minister. As I said last week, Iraqis are fed up with economic stagnation, endemic corruption, and mismanagement. They want better from their leaders, and they want accountability.

Iraqis are also demanding their country back. Three of today’s designees – al-Lami, Qais al-Khazali and Laith al-Khazali – were directed by Iranian regime when they or the armed groups they lead committed serious human rights abuses. Iraqis have paid a steep and bloody price for the malign influence of Iranian regime. Tehran claims it is exporting “revolution”. It is increasingly clear to us and the people of the region, however, that the theocracy’s top export is corruption and repression.

As for Khamis al-Khanjar, he’s wielded significant political influence through the bribery of Iraqi political figures. The Iraqi people are protesting corruption of this very sort.

The U.S. Government continues to support Iraq’s security, stability, and sovereignty. As the Secretary has said on many occasions, we are a force for good. We are the largest donor of humanitarian, stabilization, demining, and security assistance to Iraq, and we want to maintain and expand that role to include helping with economic reform to create jobs for Iraqis and Americans alike. We offer an unparalleled partnership for the Iraqi people, but we need to see Iraqi leaders committed to that partnership – equally committed to that partnership.

With that, I’ll now take some questions.

MS ORTAGUS: Matt.

QUESTION: I just – so when the Secretary and you have, in the past, over the past couple weeks, warned that Iraqi officials themselves – not only militia leaders or politicians, but actual government officials – could be subjected to sanctions for their actions, why not take that step today?

ASSISTANT SECRETARY SCHENKER: Well, thanks, Matt. Listen, GLOMAG in particular has a very high evidentiary standard. They take a long time to put together packages. If you want to know all the details and how long they take in particular, we’ve got Marshall Billingslea sitting over here somewhere. Where is he?

MS ORTAGUS: Over here.

ASSISTANT SECRETARY SCHENKER: Over here, from Treasury. He’s going to – we’re going to answer some questions.

QUESTION: You let him in the building?

MS ORTAGUS: It’s Friday. (Laughter.)

ASSISTANT SECRETARY SCHENKER: But we’re not done. This is an ongoing process. We’re – these designations don’t prejudice future announcements —

QUESTION: No, I’m not suggesting —

ASSISTANT SECRETARY SCHENKER: — and we will be doing further designations in the future, which I can’t comment on right now.

QUESTION: Well, does your – does that answer mean that you just haven’t compiled enough evidence against actual official – government officials?

ASSISTANT SECRETARY SCHENKER: I’m not going to say which ones that we’re working on or we’re not working —

QUESTION: No, no, I’m not asking for names, but is that still in the works? And do you still – do you put out the same warning to them that if this continues, they’re going to get —

ASSISTANT SECRETARY SCHENKER: Yeah, so if you are a gross violator of human rights, if you are perpetrating violence against protesters, regardless of whether you are in the government or outside the government, you’re at risk of being designated, absolutely.

QUESTION: Thank you.

MS ORTAGUS: Nadia.

QUESTION: Thank you.

ASSISTANT SECRETARY SCHENKER: Hey, Nadia.

QUESTION: Thank you.

ASSISTANT SECRETARY SCHENKER: How are you?

QUESTION: Good to see you, David. So some people say – well, three of these people that you have listed are in militias that belong to Asaib Ahl al-Haq, I believe?

ASSISTANT SECRETARY SCHENKER: Yes.

QUESTION: Some people will say, what is the effect of these sanctions? These guys don’t have bank accounts in the U.S., they don’t travel to the U.S., so it’s just symbolic sanctions. So how do you respond to that?

ASSISTANT SECRETARY SCHENKER: Well, we are holding these people to account. When possible, we’re going after the assets. Regardless of whether the Iraqi Government holds these people to account, we are holding them to account in the ways that we can. And there is an impact, but it is first and foremost symbolic, but in many cases also has a financial impact on the ability of these people to travel and do business elsewhere.

QUESTION: Would you also – sorry, would you also hold the Iraqi Government officials who deal with them accountable? Will they be also under sanction if they deal with them directly, with —

ASSISTANT SECRETARY SCHENKER: I’m going to defer to Marshall on that. My belief is yes.

MS ORTAGUS: We’ll follow up. We’ll get that answer for you.

Francesco.

QUESTION: Hi, thanks.

ASSISTANT SECRETARY SCHENKER: Hi.

QUESTION: How worried are you about Iran – Iran’s involvement in the negotiations for the formation of the new government in Baghdad, and will you be ready to work with any prime minister if he’s – you feel he’s too close to Iran?

ASSISTANT SECRETARY SCHENKER: Well, okay, there’s two parts to that question. Listen, the United States Government will work with anyone in the Iraqi Government who is willing to put Iraqi interests first. Right. This is a sine qua non. But we see in the process of establishing a new government or determining who the next prime minister will be that Qasem Soleimani is in Baghdad working this issue. It seems to us that foreign terrorist leaders, or military leaders, should not be meeting with Iraqi political leaders to determine the next premier of Iraq, and this is exactly what the Secretary says about being perhaps the textbook example of why Iran does not behave and is not a normal state. This is not normal. This is not reasonable. This is unorthodox and it is incredibly problematic, and it is a huge violation of Iraqi sovereignty.

MS ORTAGUS: Humeyra.

QUESTION: Thank you for this. Over the past couple of days, there has been some reports about Pentagon officials citing fresh intelligence about maybe potential new aggression from Iran. Do you have similar intelligence? What targeted and specific and new steps would you be taking to counter that to avoid another Abqaiq?

ASSISTANT SECRETARY SCHENKER: Listen, there’s a couple of different reports coming out about Iran. There’s been great attention lately being paid to these reports about Iranian ballistic missiles being stored in Iraq. This is something that actually Secretary Pompeo tweeted about in 2018, and something that I have said for the past four or five months on the record and on background to the bullpen and elsewhere, to all of you. And I think this is drawing greater attention particularly as Iranian-backed militias are now shelling Iraqi bases with American and Anti-ISIS Coalition forces on them – Balad, al-Asad, et cetera.

So this is something of great concern. The Iranians oftentimes, or have certainly in the past taken aggressive action when they feel under pressure. We see that in the response to, for example, the maximum pressure campaign working over the months. The past five, six months, Iran has become increasingly more aggressive. There is a trajectory, right, where they have first increased the operational tempo of the Houthis against the Saudis, then raised the rhetoric and the temperature in Iraq against U.S. personnel, moving on from there scuttling boats in Fujairah, then kidnapping boats, then shooting down U.S. drones in international airspace, and most recently Abqaiq, targeting directly with their own missiles Saudi oil facilities.

QUESTION: There – sorry, so you can confirm that attack on Balad? Is that what – you just mentioned – I just want to make sure.

ASSISTANT SECRETARY SCHENKER: An attack on Balad occurred.

QUESTION: There’s one that was just reported I guess overnight.

ASSISTANT SECRETARY SCHENKER: An attack occurred. What would I —

QUESTION: Yeah.

ASSISTANT SECRETARY SCHENKER: Sorry, the —

QUESTION: I mean, you mentioned it.

ASSISTANT SECRETARY SCHENKER: I’d say that we’re waiting for full evidence, but —

QUESTION: All right.

ASSISTANT SECRETARY SCHENKER: — if past is any – if past is prologue, I’d say there’s a good chance it was Iran that’s behind it.

QUESTION: And then you seem to suggest right now that the maximum pressure campaign is a success because it has resulted in greater Iranian aggression and shooting down U.S. drones.

ASSISTANT SECRETARY SCHENKER: I – no.

QUESTION: Well, that’s —

ASSISTANT SECRETARY SCHENKER: Maybe that’s what you inferred.

QUESTION: No, no, no, that’s – that’s – well, no, that’s I think the way —

ASSISTANT SECRETARY SCHENKER: The pressure campaign is working. They are clearly under fear and pressure, and they are lashing out. They are also —

QUESTION: Yeah, but if that’s a success, I mean —

ASSISTANT SECRETARY SCHENKER: They’re also having double-digit negative growth.

QUESTION: Fair enough.

ASSISTANT SECRETARY SCHENKER: The people in the streets are protesting against the regime for its corruption and for its economic mismanagement —

QUESTION: Yeah, but surely there’s —

ASSISTANT SECRETARY SCHENKER: — for spending all the money of the Iranian people on militias abroad, like in —

QUESTION: Surely the metric – surely the metric for the success of U.S. policy, foreign policy anywhere, not just with Iran, is that the country – the other country is less aggressive and less likely to shoot down U.S. drones or attack U.S. bases or threaten —

ASSISTANT SECRETARY SCHENKER: There is – no, Matt, there’s – to be fair, there – things sometimes get worse before they get better in those terms.

MS ORTAGUS: Okay, Said.

QUESTION: Thank you. Thank you, sir. Should the United States take some blame for the current situation in Iraq? I mean, after all, Qais al-Khazali, Laith al-Khazali, al-Lami, Asaib Ahl al-Haq, al-Hashd Shaabi, they were all – they have been there for a very long, long time. In fact, they were – they flourished during the years of the occupation and sometimes cooperating with the Americans and so on. That’s one.

And second, would you support, let’s say, redrafting another constitution, because this constitution is really what thrusted Iraq where it is today. Thank you.

ASSISTANT SECRETARY SCHENKER: Yeah, thank you. So I’m not going to weigh in about whether we should take blame for Qais al-Khazali or Laith al-Khazali. These people were there. They’re indigenous to Iran. They existed – U.S. Forces did not kill them. We tried to work with whoever we could work with at the time.

That said, whether Iraq should have a new constitution, this is up to the people of Iraq. I can tell you right now they are working on a new electoral law. They are working on developing an independent electoral commission. But yeah, they certainly need reforms. The politicians – many of the people on the council of representatives, Iraqi people say that they are not accountable to their constituents. And I don’t know what the solution is for that, but the Iraqi people, I think, want some significant reform, both economic reform, fight against corruption, and in terms of their political system.

MS ORTAGUS: Go ahead, (inaudible).

QUESTION: Yes. Yesterday in a briefing, a senior official said Iraq is limited in what they can do in terms of sovereignty. How you are planning to help them? What is the U.S. strategy, just only sanctions?

ASSISTANT SECRETARY SCHENKER: We’re doing sanctions. We’re working to help Iraq Government strengthen institutions. We are encouraging neighbors not to meddle and undermine these institutions within the country and to corrupt politicians. So we are doing what we can. We are 5,000 miles away. We are the leading provider of foreign assistance to Iraq, and we work very closely with the Iraqi Government. But as Adil Abdul-Mahdi has said, Iran is our neighbor; the United States is our friend. I believe we are a force of good there, but we are also 5,000 miles away. We are helping fight ISIS in Iraq, and we are helping to build a capable security apparatus, and we are trying to hold accountable those who are killing protesters, inciting violence, and undermining the basic rights of the Iraqi people.

At the same time, we are helping the Iraqi people by doing things that the Iraqi people are demanding that their government has not been successful with. We have, over the past four months, I believe, rehabilitated some 500 schools, 100-plus hospitals, 50 water treatment facilities. That’s over – sorry, over the past four years. So we are doing things that create a better environment for the government to be able to handle difficult problems.

MS ORTAGUS: Lara.

QUESTION: Thanks. The sanctions against the three people who are linked to Iranian-backed militias, I’m wondering if the State Department is also considering sanctions or Treasury considering sanctions against the sovereign government forces of Iraq that have cracked down on the Iraqi people. And secondly, I just want to clarify something. When you’re talking about the maximum pressure campaign and how that has spawned more aggressive actions by Iran, would you include its crackdown on its own people? Is the maximum pressure campaign a driver for these protests in Iran?

ASSISTANT SECRETARY SCHENKER: Well, I’ll start with Iran. Listen, I think that the sanctions have put additional pressure on the Iranian Government financially, forcing it to make more difficult choices, and so maybe this has brought into clearer relief for the Iranian people just how corrupt and I think callous their leadership is to the needs of the Iranian people, that they would be prioritizing at a higher level, for example, sending missiles to the Houthis or backing the Assad regime in Syria or funding Hizballah to several hundred – $700 million a year perhaps rather than providing basic services to their own people. So I think this has exacerbated an already frustrated situation for an already frustrated people.

As for whether the United States Government will sanction the institution of the security forces in Iraq, we don’t comment on things like that.

QUESTION: Or its leaders?

ASSISTANT SECRETARY SCHENKER: Individuals – like I said, if we can ascertain who they are, certainly they would be something that would be well within the purview of our legal authorities.

MS ORTAGUS: Okay, we’ll do one more. Go ahead.

QUESTION: Thank you. Ahmed of Voice of America Persian Service. My question is about Iran, mentioned one too many times here.

ASSISTANT SECRETARY SCHENKER: Yeah.

QUESTION: Do you have any – I mean, can the State Department verify any number of death tolls in Iran? Is it around couple of hundreds, is it a thousand? And my second question is that —

ASSISTANT SECRETARY SCHENKER: Did Brian Hook say that yesterday?

MS ORTAGUS: He talked about it yesterday, yeah.

ASSISTANT SECRETARY SCHENKER: I think it’s hundreds.

MS ORTAGUS: Do you have something that Brian – a question about something Brian didn’t brief yesterday, something related to today?

QUESTION: Yes. Yeah, more or less. So —

QUESTION: I have something.

MS ORTAGUS: No, you’re done for today.

QUESTION: What?

QUESTION: So this is – December is a month that the U.S. would be the rotating head of the United Nations Security Council.

ASSISTANT SECRETARY SCHENKER: Yes, yes.

QUESTION: Would you take this opportunity to exert any kind of pressure on the regime in Iran, especially the United Nations Security Council Resolution 2231? On October next year it’s coming to an end, and there are two issues there: Iran can buy arms, and also Qasem Soleimani will be released of his restriction to travel.

ASSISTANT SECRETARY SCHENKER: Yeah, listen, the Soleimani UNSCR that banning – bans his travel is – obviously we consider this to be a very important resolution. Likewise, the Secretary has spoken many times publicly about Iran’s problematic behavior and how much worse it would be in some – I don’t know, what is it, 12 months from now, when Iran can – according to the UN could – when the ban or the limitation on their export – arms export stops. So yeah, it would be something that I’m sure that USUN is looking at and would be a priority for us.

MS ORTAGUS: I think Kelly Craft did a press conference today, so you might want to check – I think it was today.

QUESTION: Yes.

MS ORTAGUS: Yeah. So you might want to check her. She might be talking about this, yeah.

QUESTION: (Off-mike.)

ASSISTANT SECRETARY SCHENKER: Yeah. Yeah, was there anything else I missed on —

QUESTION: You don’t have the – any figures that – I’m sorry, the State Department can state and verify?

ASSISTANT SECRETARY SCHENKER: Oh, the figures. Yeah, no, I – it was – I think it was in the – I don’t know if we verified them. I think the figure that is generally being bandied about is in the low hundreds.

MS ORTAGUS: To a – yeah, we don’t —

ASSISTANT SECRETARY SCHENKER: But we really don’t know.

QUESTION: Can – you probably won’t have an answer to this, but the House – can you take this question if you don’t have an answer? The House just passed a legislation opposing settlements, Israeli settlements, and also —

MS ORTAGUS: That’s a big surprise. No, we can’t take the question.

QUESTION: Why not? And also saying that Israel should not be allowed to annex the Jordan Valley. So since the Secretary just met with Prime Minister Netanyahu and you were there, presumably, right? Both of you.

ASSISTANT SECRETARY SCHENKER: Well, it was actually – it was a four eyes meeting, but I did talk to the Secretary —

MS ORTAGUS: Meaning it was the two of them. It was a one-on-one.

ASSISTANT SECRETARY SCHENKER: Yeah, sorry. I can tell you that —

MS ORTAGUS: Four eyes —

QUESTION: Oh, oh, oh, oh. Sorry. I thought you were being —

ASSISTANT SECRETARY SCHENKER: So I can tell you that there’s —

QUESTION: I thought we were going back to the schoolyard insult. (Laughter.)

ASSISTANT SECRETARY SCHENKER: Sorry. Yeah, no, no, no. So it was a one-on-one, but I can tell you I spoke with the Secretary. I can tell you that there was no annexation plan, full or partial, for any part of the West Bank was presented to – by Israel to the United States during the meeting, and that has long been the U.S. Government position, that the ultimate disposition of territory is to be determined between the parties.

QUESTION: Okay. Well, could you find out, Morgan, or could you from your bureau people whether there is any response to the bill that just passed the House?

MS ORTAGUS: To the House?

QUESTION: Yeah.

MS ORTAGUS: Probably not.

QUESTION: The House of Representatives.

MS ORTAGUS: Yeah. Yeah, thank you. I figured that.

QUESTION: Well, thanks.

MS ORTAGUS: Okay. Happy holidays, everybody.

Links:

OFAC Notice

State Department Press Release

State Department Briefing

↧

December 9, 2019: OFAC issues 2 new Venezuela FAQs

December 10, 2019, 6:15 am

≫ Next: December 9, 2019: Global Magnitsky changes + 2 new Venezuela designations

≪ Previous: December 6, 2019: OFAC designates Iraqis under Global Magnitsky sanctions

On Monday, OFAC added the following 2 Frequently Asked Questions (FAQs) under its Venezuela sanctions program:

808. Do I need a specific license from OFAC to file a suit in U.S. court against a person designated or blocked pursuant to Venezuela-related sanctions? Does a U.S. court, or its personnel, need a specific license from OFAC to hear such a case?

No. A specific license from OFAC is not ordinarily required to initiate or continue U.S. legal proceedings against a person designated or blocked pursuant to OFAC’s Venezuela sanctions program, or for a U.S. court, or its personnel, to hear such a case. However, a specific license from OFAC is required for the entry into a settlement agreement or the enforcement of any lien, judgment, or other order through execution, garnishment, or other judicial process purporting to transfer or otherwise alter or affect property or interests in property blocked pursuant to the Venezuela Sanctions Regulations (31 C.F.R. Part 591). This includes the purported creation or perfection of any legal or equitable interests (including contingent or inchoate interests) in blocked property. While terminology may vary in different jurisdictions and proceedings, a specific license from OFAC would be required for measures such as:

•Taking Possession (Actual or Constructive)

•Seizing

•Levying Upon

•Attaching

•Encumbering

•Pledging

•Conveying

•Selling (Final or Contingent)

•Freezing

•Assuming or Maintaining Custody

•Sequestering

For additional information, see 31 C.F.R. §§ 591.309, 591.310, 591.407 and 591.506. [12-09-2019]

809. I hold a writ of attachment on shares of a Government of Venezuela entity whose property and interests in property are blocked pursuant to the Venezuela Sanctions Regulations. Am I authorized to prepare for and hold an auction or other sale of the shares, contingent upon the winning bidder obtaining a license from OFAC?

No. Parties who have attached shares of an entity whose property and interests in property are blocked pursuant to the Venezuela Sanctions Regulations (31 C.F.R. Part 591) must obtain a specific license from OFAC prior to conducting an auction or other sale, including a contingent auction or other sale, or taking other concrete steps in furtherance of an auction or sale. More generally, OFAC urges caution in proceeding with any step in furtherance of measures which might alter or affect blocked property or interests in blocked property. OFAC would consider license applications seeking to authorize such activities on a case-by-case basis. For additional information, see 31 C.F.R. §§ 591.309, 591.310, 591.407 and 591.506. [12-09-2019]

Link:

OFAC Notice

New FAQs

↧

December 9, 2019: Global Magnitsky changes + 2 new Venezuela designations

December 10, 2019, 6:20 am

≫ Next: Even more Global Magnitsky designations…

≪ Previous: December 9, 2019: OFAC issues 2 new Venezuela FAQs

The Office of Foreign Assets Control has issued Global Magnitsky General License Number 1: Authorizing Certain Activities Necessary to the Wind Down of Transactions Involving Ventspils Freeport Authority, Ventspils Attistibas Agentura, Biznesa Attistibas Asociacija, and Latvijas Tranzita Biznesa Asociacija.

Additionally, the following persons:

ANDRIC, Goran, Serbia; DOB 21 Apr 1965; nationality Serbia; alt. nationality Bosnia and Herzegovina; citizen Serbia; alt. citizen United Kingdom; Gender Male (individual) [GLOMAG] (Linked To: TESIC, Slobodan).

BRKIC, Nikola, Serbia; DOB 13 Jan 1954; nationality Serbia; Gender Male (individual) [GLOMAG] (Linked To: TESIC, Slobodan).

CHANDY, King (a.k.a. CHAN DY, King; a.k.a. CHANDY, Keung; a.k.a. CHANDY, Koeung), Cambodia; DOB 01 Mar 1959; alt. DOB 01 Mar 1958; Gender Female (individual) [GLOMAG] (Linked To: KIM, Kun).

CVJETKOVIC, Sreten, Serbia; DOB 15 Jan 1961; nationality Serbia; Gender Male; National ID No. 006789921 (Serbia) expires 25 May 2025 (individual) [GLOMAG] (Linked To: TESIC, Slobodan).

KAPIDZIC, Esad (a.k.a. KAPIDZIC, Eso), Serbia; DOB 23 Jun 1959; alt. DOB 23 Jun 1958; POB Prijepolje, Montenegro; nationality Serbia; Gender Male (individual) [GLOMAG] (Linked To: TESIC, Slobodan).

KIM, Kun, Cambodia; DOB 01 Jan 1954; POB Chan Toung Village, Sralap Commune, Tbaung Khmum District, Cambodia; Gender Male; Passport N0000259216 (Cambodia) expires 10 Jun 2025; alt. Passport D0002907 (Cambodia) (individual) [GLOMAG].

LEMBERGS, Aivars, Ventspils, Latvia; DOB 26 Sep 1953; POB Jekabpils, Latvia; nationality Latvia; Gender Male (individual) [GLOMAG].

MARICIC, Ljubo, Serbia; DOB 10 Jan 1959; nationality Serbia; Gender Male (individual) [GLOMAG] (Linked To: TESIC, Slobodan).

PETROVIC, Zelimir, Serbia; DOB 01 Sep 1981; nationality Serbia; Gender Male (individual) [GLOMAG] (Linked To: TESIC, Slobodan).

PETROVIC, Zoran, Serbia; DOB 25 Apr 1969; nationality Serbia; Gender Male (individual) [GLOMAG] (Linked To: TESIC, Slobodan).

PHARA, Kim, 135, St. 110 SR., Takhmao, Kandal, Cambodia; DOB 10 Sep 1984; POB Cambodia; Gender Male; Passport N0263817 (individual) [GLOMAG] (Linked To: KIM, Kun).

PHEAP, Try (a.k.a. PHEAP, Thy), N10AB Street 271 SK. Toek Laork III, Khan Toul Kork, Phnom Penh, Cambodia; DOB 15 Jul 1965; POB Kandal Province, Cambodia; Gender Male; Passport N0239194 (Cambodia) expires 21 Feb 2008 (individual) [GLOMAG].

SARENAC, Nebojsa, Serbia; DOB 25 Dec 1977; nationality Serbia; Gender Male (individual) [GLOMAG] (Linked To: TESIC, Slobodan).

SOPHARY, Kim, 135, Street 110, Takhmao, Kandal 0811, Cambodia; DOB 12 Dec 1982; POB Kampong Cham, Cambodia; Gender Female; Passport N00013860 (Cambodia) expires 13 Aug 2024 (individual) [GLOMAG] (Linked To: KIM, Kun).

SUBOTIC, Milan, Serbia; DOB 08 Nov 1981; nationality Serbia; Gender Male (individual) [GLOMAG] (Linked To: TESIC, Slobodan).

and entities:

7 MAKARA PHARY CO., LTD., Deaum Mien, Daeum Mien, Ta Khmau, Kandal 8252, Cambodia; Company Number 00037307 (Cambodia) [GLOMAG] (Linked To: SOPHARY, Kim).

ARANEKS DOO (a.k.a. ARANEKS DOO BEOGRAD-VOZDOVAC), Bulevar Oslobodenja 166, Belgrade 11010, Serbia; Tax ID No. 110965174 (Serbia); Registration Number 21407429 (Serbia) [GLOMAG] (Linked To: TESIC, Slobodan).

BIZNESA ATTISTIBAS ASOCIACIJA (a.k.a. “BUSINESS DEVELOPMENT ASSOCIATION”), 8 – 1 Uzavas iela, Ventspils LV-3601, Latvia; Tax ID No. 40008055717 (Latvia) [GLOMAG] (Linked To: LEMBERGS, Aivars).

BUSINESS DIVERSITY LIMITED (a.k.a. BUSINESS DIVERSITY LTD), Unit 11/F, CNT Tower, 338 Hennessy Road, Wan Chai, Hong Kong; Registration Number 2421075 (Hong Kong) [GLOMAG] (Linked To: TESIC, Slobodan).

CAMBO ELITE SECURITY FORCE CO., LTD., Thmei, Ta Khmau, Ta Khmau, Kandal 8251, Cambodia; Company Number 00038610 (Cambodia) [GLOMAG] (Linked To: SOPHARY, Kim).

FALCON STRATEGIC SOLUTIONS DOO (a.k.a. FALCON STRATEGIC SOLUTIONS DOO BEOGRAD-PALILULA), Todora Manojlovica 28, Belgrade 11060, Serbia; Tax ID No. 110427636 (Serbia); Registration Number 21348953 (Serbia) [GLOMAG] (Linked To: TESIC, Slobodan).

FINROST LIMITED, Eleniko Building, Floor 4, Fla, 7 Stasandrou, Nicosia 1060, Cyprus; Registration Number HE 357180 (Cyprus) [GLOMAG] (Linked To: TESIC, Slobodan).

K D RUBBER PLANTATION CO., LTD., 135, 110, Thmei, Ta Khmau, Ta Khmau, Kandal 8251, Cambodia; Company Number 00023622 (Cambodia) [GLOMAG] (Linked To: CHANDY, King).

LATVIJAS TRANZITA BIZNESA ASOCIACIJA (a.k.a. LATVIAN TRANSIT BUSINESS ASSOCIATION; a.k.a. TRANSIT BUSINESS ASSOCIATION OF LATVIA), 66 Dzintaru iela, Ventspils LV-3602, Latvia; Tax ID No. 40008008110 (Latvia) [GLOMAG] (Linked To: LEMBERGS, Aivars).

M D S THMORDA S E Z CO., LTD. (a.k.a. MDS THMORDA SEZ), 10 AB, 271, Tuek L’ak Bei, Tuol Kouk, Phnom Penh, Cambodia; Company Number 00019416(Cambodia) [GLOMAG] (Linked To: PHEAP, Try).

M. D. S. IMPORT EXPORT CO., LTD. (a.k.a. MDS IMPORT EXPORT; a.k.a. MDS IMPORT EXPORT CO., LTD.), 10 AB, Tuek L’ak Bei, Tuol Kouk, Phnom Penh, Cambodia; Tax ID No. K005-105000833 (Cambodia); Company Number 00019488(Cambodia) [GLOMAG] (Linked To: PHEAP, Try).

MELVALE CORPORATION DOO BEOGRAD (a.k.a. PREDUZECE ZA PROIZVODNJU, PROMET I USLUGE MELVALE CORPORATION DOO, BEOGRAD STARI GRAD), Tadeusa Koscuska 56, Belgrade 11000, Serbia; Tax ID No. 104150191 (Serbia); Registration Number 20100575 (Serbia) [GLOMAG] (Linked To: SARENAC, Nebojsa).

MOONSTORM ENTERPRISES LIMITED, Elli Court, Flat No. 4, Floor No. 2, Arch. Makariou III 210, Limassol 3030, Cyprus; Registration Number HE247830 (Cyprus) [GLOMAG] (Linked To: TESIC, Slobodan).

PAPA PETROLEUM CO., LTD., 35, Voat Phnum, Doun Penh, Phnom Penh, Cambodia; Tax ID No. L001-901503571 (Cambodia); Company Number 00019413 (Cambodia) [GLOMAG] (Linked To: PHEAP, Try).

ROMDOUL CAPITAL PAWN CO., LTD., 21, 352 Boeng Keng Kang Muoy, Chamkar Mon, Phnom Penh, Cambodia; Company Number 00005573 (Cambodia) [GLOMAG] (Linked To: PHARA, Kim).

ROMDOUL DEVELOPMENT CO., LTD., Boeng Keng Kang Moy, Chamkar Mon, Phnom Penh, Cambodia; Company Number 00024848 (Cambodia) [GLOMAG] (Linked To: PHARA, Kim).

TARDIGRADE LIMITED, Dimitriados 1, Limassol 4004, Cyprus; Registration Number C378737 (Cyprus) [GLOMAG] (Linked To: TESIC, Slobodan).

TRY PHEAP DRY PORT CO., LTD., 35, 41 110 Voat Phnum, Doun Penh, Phnom Penh, Cambodia; Tax ID No. K003-100194060 (Cambodia); Company Number 00019406(Cambodia) [GLOMAG] (Linked To: PHEAP, Try).

TRY PHEAP ENGINEERING & CONSTRUCTION CO., LTD. (a.k.a. TRY PHEAP ENGINEERING AND CONSTRUCTION CO., LTD.), 3-5 Voat Phnum, Doun Penh, Phnom Penh, Cambodia; Tax ID No. L0001-901504050 (Cambodia); Company Number 00019414 (Cambodia) [GLOMAG] (Linked To: PHEAP, Try).

TRY PHEAP GRAND ROYAL CAMBODIA CO., LTD., Voat Phnum, Doun Penh, Phnom Penh, Cambodia; Company Number 00014853 (Cambodia) [GLOMAG] (Linked To: PHEAP, Try).

TRY PHEAP GROUP CO., LTD., 3, Voat Phnum, Doun Penh, Phnom Penh, Cambodia; Company Number 00019408 (Cambodia) [GLOMAG] (Linked To: PHEAP, Try).

TRY PHEAP IMPORT EXPORT CO., LTD., 3 Voat Phnum, Doun Penh, Phnom Penh, Cambodia; Tax ID No. K003-100075533 (Cambodia); Company Number 00019401(Cambodia) [GLOMAG] (Linked To: PHEAP, Try).

TRY PHEAP OYADAV S E Z CO., LTD. (a.k.a. TRY PHEAP OU YA DAV), 1 A, 271, Tuek L’ak Bei, Tuol Kouk, Phnom Penh, Cambodia; Company Number 00019411(Cambodia) [GLOMAG] (Linked To: PHEAP, Try).

TRY PHEAP PROPERTY CO., LTD., 03 Voat Phnum, Doun Penh, Phnom Penh, Cambodia; Tax ID No. K003-901637752 (Cambodia); Company Number 00013378(Cambodia) [GLOMAG] (Linked To: PHEAP, Try).

TRY PHEAP TRAVEL & TOURS CO., LTD. (a.k.a. TRY PHEAP TRAVEL AND TOURS CO., LTD.), 3, Voat Phnum, Doun Penh, Phnom Penh, Cambodia; Tax ID No. K003-104019131 (Cambodia); Company Number 00019403 (Cambodia) [GLOMAG] (Linked To: PHEAP, Try).

VECTURA TRANS DOO (a.k.a. VECTURA TRANS DOO NOVI BEOGRAD), Narodnih Heroja 16, Belgrade, Serbia; Tax ID No. 109894091 (Serbia); Registration Number 21262358 (Serbia) [GLOMAG] (Linked To: TESIC, Slobodan).

VELCOM TRADE DOO BEOGRAD (a.k.a. VELCOM TRADE PREDUZECE ZA PROIZVODNJU PROMET I USLUGE DOO, BEOGRAD STARI GRAD), Tadeusa Koscuskog 56, Belgrade 11000, Serbia; Tax ID No. 102858071 (Serbia); Registration Number 17499858 (Serbia) [GLOMAG] (Linked To: ANDRIC, Goran).

VENTSPILS ATTISTIBAS AGENTURA (a.k.a. VENTSPILS DEVELOPMENT AGENCY; a.k.a. VENTSPILS DEVELOPMENT ASSOCIATION), Inzenieru 101A, Ventspils 3601, Latvia; Tax ID No. 40008033300 (Latvia) [GLOMAG] (Linked To: LEMBERGS, Aivars).

VENTSPILS FREEPORT AUTHORITY (a.k.a. FREEPORT OF VENTSPILS; a.k.a. FREEPORT OF VENTSPILS AUTHORITY; a.k.a. VENTSPILS FREE PORT; a.k.a. VENTSPILS FREEPORT), Jana 19, Ventspils LV-3601, Latvia [GLOMAG] (Linked To: LEMBERGS, Aivars).

were added to the SDN List under the Global Magnitsky sanctions program. Additionally, an existing designation was updated:

TECHNOGLOBAL SYSTEMS DOO BEOGRAD (a.k.a. CALIDUS TRADE DOO; a.k.a. CALIDUS TRADE DOO BEOGRAD), Maglajska 19 11000, Beograd 6, Beograd, Serbia; Registration ID 20295066 (Serbia); Tax ID No. 105012258 [GLOMAG] (Linked To: TESIC, Slobodan). -to- TEHNOGLOBAL SYSTEMS DOO BEOGRAD (a.k.a. CALIDUS TRADE DOO; a.k.a. CALIDUS TRADE DOO BEOGRAD), Maglajska 19 11000, Beograd 6, Beograd, Serbia; Registration ID 20295066 (Serbia); Tax ID No. 105012258 [GLOMAG] (Linked To: TESIC, Slobodan).

As of when I wrote this up, there was no press release about these designations. However, based on the number of parties, and the fact that there are a lot of commercial entities involved, my guess is that these are corruption-based, not due to human rights abuses (Global Magnitsky covers both).

Lastly, two people were also added to the Venezuela sanctions program:

VIZCAINO GIL, Gustavo Adolfo, Caracas, Capital District, Venezuela; DOB 03 May 1966; Gender Male; Cedula No. 6297704 (Venezuela) (individual) [VENEZUELA].

DUGARTE PADRON, Juan Carlos, Caracas, Capital District, Venezuela; DOB 16 Oct 1955; Gender Male; Cedula No. 4353212 (Venezuela) (individual) [VENEZUELA].

The State Department issued a press release about the Venezuela designations:

The United States Takes Action Against Maduro-Aligned Individuals

MEDIA NOTE

OFFICE OF THE SPOKESPERSON

DECEMBER 9, 2019

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On December 9, 2019, the United States sanctioned two officials aligned with the former Maduro regime pursuant to Executive Order 13692, as amended, which authorizes the designation of any person determined to be a current or former official of the Government of Venezuela. Gustavo Adolfo Vizcaino Gil and Juan Carlos Dugarte Padron used their position as Director General of the Government of Venezuela’s Administrative Service of Identification, Migration, and Immigration (SAIME) to corruptly enrich themselves at the expense of Venezuelans seeking passport services. Vizcaino was Director General from April 2016 until June 2018, when Dugarte replaced him.

During Vizcaino’s tenure, SAIME charged exorbitant fees from passport applicants, from which he personally profited. Some passports were sold to non-Venezuelan citizens and other applicants never received passports, even after illicitly being charged thousands of dollars. Dugarte also received kickbacks and was publicly implicated in corrupt dealings for the sale of passports.

It is unconscionable that Venezuelans may be unable to obtain a passport or have to pay excessive fees due to corruption, as they continue to flee the devastating conditions in Venezuela that Maduro and his corrupt associates have created. This is yet another cause of the misery that millions of Venezuelans now suffer.

With our democratic partners in the region and around the world, the United States will continue to support the people of Venezuela, interim President Guaido, and the National Assembly.

So, here’s the question: what’s the upside of sanctioning Vizcaino, who is now a former official? How could he ever be removed, absent the program’s termination? How does a punitive designation, with no achievable result to satisfy US interests, advance US foreign policy, much less international security and stability? As a deterrent?

Links:

OFAC Notice

Global Magnitsky General License 1

State Department Press Release

↧

Even more Global Magnitsky designations…

December 10, 2019, 7:53 am

≫ Next: OFAC adds and updates Iran listings, issues new FAQs

≪ Previous: December 9, 2019: Global Magnitsky changes + 2 new Venezuela designations

Earlier today, OFAC added the following persons:

AL-WARFALLI, Mahmud (a.k.a. AL-WERFALLI, Mahmoud; a.k.a. AL-WERFALLI, Mahmoud Mustafa Busayf), Benghazi, Libya; DOB 1978; nationality Libya; Gender Male (individual) [GLOMAG].

ANWAR, Rao (a.k.a. AHMED, Rao Anwar; a.k.a. KHAN, Anwar Ahmed; a.k.a. KHAN, Anwar Ahmed Rao; a.k.a. KHAN, Rao Anwar Ahmed), Pakistan; DOB 01 Jan 1959; POB Karachi, Pakistan; nationality Pakistan; Gender Male; Passport MU-4112252 (Pakistan) issued 27 May 2014 expires 26 May 2019 (individual) [GLOMAG].

AUNG, Aung, Burma; DOB 1973; Gender Male (individual) [GLOMAG].

BALUKU, Musa (a.k.a. BALUKU, Seka; a.k.a. KAJUJU, Mzee), Congo, Democratic Republic of the; DOB 1976; alt. DOB 1975 to 1976; POB Kasese District, Rwenzururu Sub-Region, Western Uganda; nationality Uganda; Gender Male (individual) [GLOMAG].

GARANG, Angelo Kuot, Juba, South Sudan; DOB 12 Mar 1983; nationality South Sudan; Gender Male (individual) [GLOMAG].

HLAING, Min Aung, Burma; DOB 1956; Gender Male (individual) [GLOMAG].

KASADHA, Amisi (a.k.a. KASAADA, Muzamil; a.k.a. KASADA, Kasadha; a.k.a. KIRBAKI, Muzamir; a.k.a. KIRIBAKI, Muzamir; a.k.a. “Kalume”; a.k.a. “Karume”), Congo, Democratic Republic of the; DOB 1975 to 1981; POB Iganga District, Busoga Region, Uganda; nationality Uganda; Gender Male (individual) [GLOMAG].

KIBIRIGE, Amigo (a.k.a. AMIGO, Mzee; a.k.a. AMIGO, Simba; a.k.a. KIBIRGE, Amigo; a.k.a. MUHAMMAND, Kibirige), Congo, Democratic Republic of the; DOB 1975 to 1979; POB Masaka District, Central Region, Uganda; nationality Uganda; Gender Male (individual) [GLOMAG].

KOCNER, Marian, Slovakia; DOB 17 May 1963; POB Ruzomberok, Slovakia; nationality Slovakia; Gender Male; Passport 4305176196 (Slovakia) expires 31 Mar 2025 (individual) [GLOMAG].

KUAJIEN, Michael (a.k.a. KUAJIAN, Michael; a.k.a. KUAJIEN DUER MAYOK, Michael), Nairobi, Kenya; DOB 01 Jan 1979; nationality South Sudan; Gender Male (individual) [GLOMAG].

LAM, John Top (a.k.a. TUT, John Top Lam), Nairobi 248-00100, Kenya; DOB 12 Sep 1979; POB Ayod, South Sudan; nationality South Sudan; Gender Male; Passport R00339720 (South Sudan) issued 21 Mar 2016 expires 21 Mar 2021; National ID No. 000119903 (South Sudan) (individual) [GLOMAG].

LUMISA, Muhammed (a.k.a. LUMISA, Muhamad; a.k.a. “KATO, L.”; a.k.a. “LUMINSA”; a.k.a. “LUMWISA”; a.k.a. “Mukade”; a.k.a. “Mukake”), Congo, Democratic Republic of the; DOB 1959; alt. DOB 1959 to 1965; POB Kampala District, Central Region, Uganda; nationality Uganda; Gender Male (individual) [GLOMAG].

MUHAMMAD, Kayiira (a.k.a. KAYIRA, Muhammad Mzee; a.k.a. MAHAMMAD, Kayiira; a.k.a. MUHAMADI, Kahira; a.k.a. “Kaida”; a.k.a. “Karida”; a.k.a. “Ogundipe”), Congo, Democratic Republic of the; DOB 1963 to 1969; POB Kampala District, Central Region, Uganda; nationality Uganda; Gender Male (individual) [GLOMAG].

MUORWEL, Malual Dhal (a.k.a. MUORWEL MALUAL, Malual Dhal), Luri, South Sudan; DOB 01 Jan 1975; nationality South Sudan; Gender Male (individual) [GLOMAG].

OO, Than, Burma; DOB 12 Oct 1973; Gender Male (individual) [GLOMAG].

SEGUJJA, Elias (a.k.a. SUGUJA, Fezza; a.k.a. “Faiza”; a.k.a. “Feeza”; a.k.a. “Mulalo”), Congo, Democratic Republic of the; DOB 1969 to 1971; POB Kampala District, Central Region, Uganda; nationality Uganda; Gender Male (individual) [GLOMAG].

THIONGKOL, Abud Stephen (a.k.a. KOL, Abud Stephen Thiong), South Sudan; DOB 23 Feb 1962; Gender Male (individual) [GLOMAG].

WIN, Soe, Burma; DOB 01 Mar 1960; Gender Male (individual) [GLOMAG].

and entities:

HOTEL HOLDING, S.R.O., Bratislava, Slovakia; Tax ID No. 2023153495 (Slovakia); Registration Number 45946892 (Slovakia) [GLOMAG] (Linked To: KOCNER, Marian).

INTERNATIONAL INVESTMENT DEVELOPMENT HOLDING A.S. (f.k.a. R.E.N.T.A.L A.S.), Bratislava, Slovakia; Tax ID No. 2022037809 (Slovakia); Registration Number 35875551 (Slovakia) [GLOMAG] (Linked To: KOCNER, Marian).

INTERNATIONAL INVESTMENT HOTELS HOLDINGS A.S. (a.k.a. RENTA A.S.), Bratislava, Slovakia; Tax ID No. 2021969268 (Slovakia); Registration Number 35873990 (Slovakia) [GLOMAG] (Linked To: KOCNER, Marian).

SPRAVA A INKASO POHLADAVOK, S.R.O. (f.k.a. SPRAVA SLUZIEB DONOVALY S.R.O.), Bratislava, Slovakia; Tax ID No. 2022942592 (Slovakia) [GLOMAG] (Linked To: KOCNER, Marian).

SPRAVA A INKASO ZMENIEK, S.R.O., Bratislava, Slovakia; Tax ID No. 2120543876(Slovakia); Registration Number 50335839 (Slovakia) [GLOMAG] (Linked To: KOCNER, Marian).

TRANZ-TEL, A.S. (f.k.a. NORAM – AZD, A.S.), Krizna 47, Bratislava 1 – Mestska Cast Ruzinov, Bratislava 81107, Slovakia; Tax ID No. 202141989 (Slovakia); Registration Number 35720514 (Slovakia) [GLOMAG] (Linked To: KOCNER, Marian

to its Global Magnitsky sanctions program. It appears that the Kocner and the entity designations are corruption-related, and the Burma designations are more likely than not human rights abuse-related. The rest I’m not so sure about.

This is my main beef about the Global Magnitsky program – that it combines two different types of bad behavior. Two separate programs might be easier to manage.

Link:

OFAC Notice

↧

OFAC adds and updates Iran listings, issues new FAQs

December 11, 2019, 8:41 am

≫ Next: December 12, 2019: OFAC adds to Nicaragua sanctions

≪ Previous: Even more Global Magnitsky designations…

Today, OFAC added a person:

KHEDRI, Abdolhossein (a.k.a. KHEDRI, Abdolhossein Heid; a.k.a. KHEDRI, Abdul Hossein; a.k.a. KHODRI, Abed Al Hsein Heid), Iran; DOB May 1971; POB Bushehr Province, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE).

and some entities:

GATEWICK LLC (a.k.a. GATEWICK AVIATION SERVICES; a.k.a. GATEWICK FREIGHT AND CARGO; a.k.a. “GATEWICK”), Office No. M22, 1st Floor Dnata Building Freight Gate No. 4, Dubai Airport Free Zone, United Arab Emirates; Freight Gate 3, DAFZA, Dubai, United Arab Emirates; P.O. Box 52404, United Arab Emirates; P.O. Box 120597, United Arab Emirates; Website http://www.gatewick.com; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 222112 (United Arab Emirates) [SDGT] [IFSR] (Linked To: MAHAN AIR).

GOMEI AIR SERVICES CO., LTD., 3/F, The Strand, 49 Bonham Strand, Sheung Wan, Hong Kong; B-1,2, Tower1, 120Liuhua Rd Dongfang Hotel, Guangzhou, China; Room 1403B, Pearl River Int’l Building, 112 Yuehua Road, YueXiu District, Guangzhou, China; Email Address cargores@gomei.com.hk; alt. Email Address cargores@gzgomei.cn; alt. Email Address mahan-gz@m3eliteclub.com; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: MAHAN AIR).

JAHAN DESTINATIONS TRAVEL AND TOURISM LLC, G/F, Falcon Tower, Riggat Al Buteen, Deira, P.O. Box 125327, Dubai, United Arab Emirates; Office No. 4, Riqat Albutain, Deira, Dubai, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions; Tourism License No. 585026 (United Arab Emirates); Registration Number 110323 (United Arab Emirates) [SDGT] [IFSR] (Linked To: MAHAN AIR).

KHEDRI JAHAN DARYA CO (a.k.a. KHEDRI JAHAN DARYA SHIPPING PORT COMMERCIAL COMPANY), 1st Floor No. 11 Before Davood Eslami Street Junction Gilane Gharbi Street, 2nd Boostan Street, Pasdaran Street, Tehran, Tehran Province 1664867853, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Identification Number IMO 4213219 [SDGT] [IFSR] (Linked To: KHEDRI, Abdolhossein).

MARITIME SILK ROAD LLC, Muscat, Oman; Additional Sanctions Information – Subject to Secondary Sanctions; Commercial Registry Number 1096241 (Oman) [SDGT] [IFSR] (Linked To: KHEDRI, Abdolhossein).

and 2 vessels:

GENAVA 11 (f.k.a. GOSTARESH SW 8301) (EPDE7) Iran flag; Additional Sanctions Information – Subject to Secondary Sanctions; Vessel Registration Identification IMO 9804617 (vessel) [SDGT] [IFSR] (Linked To: KHEDRI JAHAN DARYA CO).

GENAVA 12 (EPDA4) Iran flag; Additional Sanctions Information – Subject to Secondary Sanctions; Vessel Registration Identification IMO 9776523 (vessel) [SDGT] [IFSR] (Linked To: KHEDRI JAHAN DARYA CO).

to its Iran sanctions program. It also put a bunch of Mahan Air aircraft under secondary sanctions more clearly (by adding the verbiage to the listings), and/or added them to the non-proliferation program (NPWMD) – and updated the Mahan Air listing, to boot:

EK-30064; Aircraft Construction Number (also called L/N or S/N or F/N) 464; Aircraft Manufacture Date 17 May 1988; Aircraft Model A300B4-605R; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EK-30064; Aircraft Construction Number (also called L/N or S/N or F/N) 464; Aircraft Manufacture Date 17 May 1988; Aircraft Model A300B4-605R; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MHA; Aircraft Construction Number (also called L/N or S/N or F/N) 160; Aircraft Manufacture Date 17 Sep 1981; Aircraft Model A300B2K-3C; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MHA; Aircraft Construction Number (also called L/N or S/N or F/N) 160; Aircraft Manufacture Date 17 Sep 1981; Aircraft Model A300B2K-3C; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MHF; Aircraft Construction Number (also called L/N or S/N or F/N) 55; Aircraft Manufacture Date 01 Mar 1978; Aircraft Model A300B4-103; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MHF; Aircraft Construction Number (also called L/N or S/N or F/N) 55; Aircraft Manufacture Date 01 Mar 1978; Aircraft Model A300B4-103; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MHG; Aircraft Construction Number (also called L/N or S/N or F/N) 204; Aircraft Manufacture Date 29 Jul 1982; Aircraft Model A300B4-203; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MHG; Aircraft Construction Number (also called L/N or S/N or F/N) 204; Aircraft Manufacture Date 29 Jul 1982; Aircraft Model A300B4-203; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MHJ; Aircraft Construction Number (also called L/N or S/N or F/N) 857; Aircraft Manufacture Date 18 Jun 1998; Aircraft Model A320-232; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MHJ; Aircraft Construction Number (also called L/N or S/N or F/N) 857; Aircraft Manufacture Date 18 Jun 1998; Aircraft Model A320-232; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MHL; Aircraft Construction Number (also called L/N or S/N or F/N) 175; Aircraft Manufacture Date 02 Feb 1982; Aircraft Model A300B4-203; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MHL; Aircraft Construction Number (also called L/N or S/N or F/N) 175; Aircraft Manufacture Date 02 Feb 1982; Aircraft Model A300B4-203; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MHM; Aircraft Construction Number (also called L/N or S/N or F/N) 90; Aircraft Manufacture Date 05 Nov 1980; Aircraft Model A300B2K-3C; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MHM; Aircraft Construction Number (also called L/N or S/N or F/N) 90; Aircraft Manufacture Date 05 Nov 1980; Aircraft Model A300B2K-3C; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MHO; Aircraft Construction Number (also called L/N or S/N or F/N) 488; Aircraft Manufacture Date 13 Jan 1989; Aircraft Model A310-304; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MHO; Aircraft Construction Number (also called L/N or S/N or F/N) 488; Aircraft Manufacture Date 13 Jan 1989; Aircraft Model A310-304; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MHP; Aircraft Construction Number (also called L/N or S/N or F/N) 244; Aircraft Manufacture Date 09 Mar 1983; Aircraft Model A300B2K-3C; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MHP; Aircraft Construction Number (also called L/N or S/N or F/N) 244; Aircraft Manufacture Date 09 Mar 1983; Aircraft Model A300B2K-3C; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MMA; Aircraft Manufacture Date 08 Sep 1993; Aircraft Model A340-311; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 20; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MMA; Aircraft Manufacture Date 08 Sep 1993; Aircraft Model A340-311; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 20; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MMB; Aircraft Manufacture Date 07 Dec 1994; Aircraft Model A340-311; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 56; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MMB; Aircraft Manufacture Date 07 Dec 1994; Aircraft Model A340-311; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 56; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MMC; Aircraft Manufacture Date 18 Jun 1999; Aircraft Model A340-313X; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 282; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MMC; Aircraft Manufacture Date 18 Jun 1999; Aircraft Model A340-313X; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 282; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MMJ; Aircraft Manufacture Date 05 Oct 1989; Aircraft Model A310-304; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 526; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MMJ; Aircraft Manufacture Date 05 Oct 1989; Aircraft Model A310-304; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 526; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MMV; Aircraft Manufacture Date 12 Aug 1987; Aircraft Model BAe 146-200; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2079; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MMV; Aircraft Manufacture Date 12 Aug 1987; Aircraft Model BAe 146-200; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2079; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNA; Aircraft Construction Number (also called L/N or S/N or F/N) 811; Aircraft Manufacture Date 18 Feb 1993; Aircraft Model B.747-422; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 24383 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNA; Aircraft Construction Number (also called L/N or S/N or F/N) 811; Aircraft Manufacture Date 18 Feb 1993; Aircraft Model B.747-422; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 24383; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNB; Aircraft Construction Number (also called L/N or S/N or F/N) 740; Aircraft Manufacture Date 20 Jul 1989; Aircraft Model B.747-422; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 24363 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNB; Aircraft Construction Number (also called L/N or S/N or F/N) 740; Aircraft Manufacture Date 20 Jul 1989; Aircraft Model B.747-422; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 24363; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNC; Aircraft Construction Number (also called L/N or S/N or F/N) 973; Aircraft Manufacture Date 12 Apr 1993; Aircraft Model B.747-422; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 26879 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNC; Aircraft Construction Number (also called L/N or S/N or F/N) 973; Aircraft Manufacture Date 12 Apr 1993; Aircraft Model B.747-422; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 26879; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNE; Aircraft Construction Number (also called L/N or S/N or F/N) 641; Aircraft Manufacture Date 14 Apr 1986; Aircraft Model B747-3B3; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 23480 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNE; Aircraft Construction Number (also called L/N or S/N or F/N) 641; Aircraft Manufacture Date 14 Apr 1986; Aircraft Model B747-3B3; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 23480; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNF; Aircraft Manufacture Date 07 Aug 1990; Aircraft Model A310-304; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 547; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MNF; Aircraft Manufacture Date 07 Aug 1990; Aircraft Model A310-304; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 547; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNG; Aircraft Construction Number (also called L/N or S/N or F/N) 401; Aircraft Manufacture Date 02 Feb 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNG; Aircraft Construction Number (also called L/N or S/N or F/N) 401; Aircraft Manufacture Date 02 Feb 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNH; Aircraft Construction Number (also called L/N or S/N or F/N) 405; Aircraft Manufacture Date 03 Feb 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNH; Aircraft Construction Number (also called L/N or S/N or F/N) 405; Aircraft Manufacture Date 03 Feb 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNI; Aircraft Construction Number (also called L/N or S/N or F/N) 408; Aircraft Manufacture Date 23 Feb 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNI; Aircraft Construction Number (also called L/N or S/N or F/N) 408; Aircraft Manufacture Date 23 Feb 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNJ; Aircraft Construction Number (also called L/N or S/N or F/N) 380; Aircraft Manufacture Date 31 Dec 1986; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNJ; Aircraft Construction Number (also called L/N or S/N or F/N) 380; Aircraft Manufacture Date 31 Dec 1986; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNK; Aircraft Construction Number (also called L/N or S/N or F/N) 618; Aircraft Manufacture Date 04 Sep 1991; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNK; Aircraft Construction Number (also called L/N or S/N or F/N) 618; Aircraft Manufacture Date 04 Sep 1991; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNL; Aircraft Construction Number (also called L/N or S/N or F/N) 623; Aircraft Manufacture Date 23 Oct 1991; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNL; Aircraft Construction Number (also called L/N or S/N or F/N) 623; Aircraft Manufacture Date 23 Oct 1991; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNM; Aircraft Construction Number (also called L/N or S/N or F/N) 773; Aircraft Manufacture Date 13 Nov 1986; Aircraft Model A300B4-605R; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNM; Aircraft Construction Number (also called L/N or S/N or F/N) 773; Aircraft Manufacture Date 13 Nov 1986; Aircraft Model A300B4-605R; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNN; Aircraft Construction Number (also called L/N or S/N or F/N) 701; Aircraft Manufacture Date 17 May 1993; Aircraft Model A300B4-605R; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNN; Aircraft Construction Number (also called L/N or S/N or F/N) 701; Aircraft Manufacture Date 17 May 1993; Aircraft Model A300B4-605R; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNO; Aircraft Construction Number (also called L/N or S/N or F/N) 595; Aircraft Manufacture Date 30 Aug 1991; Aircraft Model A310-308; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNO; Aircraft Construction Number (also called L/N or S/N or F/N) 595; Aircraft Manufacture Date 30 Aug 1991; Aircraft Model A310-308; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNP; Aircraft Construction Number (also called L/N or S/N or F/N) 620; Aircraft Manufacture Date 08 Nov 1991; Aircraft Model A310-308; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNP; Aircraft Construction Number (also called L/N or S/N or F/N) 620; Aircraft Manufacture Date 08 Nov 1991; Aircraft Model A310-308; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNQ; Aircraft Construction Number (also called L/N or S/N or F/N) 553; Aircraft Manufacture Date 08 Dec 1989; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNQ; Aircraft Construction Number (also called L/N or S/N or F/N) 553; Aircraft Manufacture Date 08 Dec 1989; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNR; Aircraft Construction Number (also called L/N or S/N or F/N) 411; Aircraft Manufacture Date 27 Mar 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNR; Aircraft Construction Number (also called L/N or S/N or F/N) 411; Aircraft Manufacture Date 27 Mar 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNS; Aircraft Construction Number (also called L/N or S/N or F/N) 414; Aircraft Manufacture Date 17 Apr 1987; Aircraft Model A300B4-603; alt. Aircraft Model MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNS; Aircraft Construction Number (also called L/N or S/N or F/N) 414; Aircraft Manufacture Date 17 Apr 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNT; Aircraft Construction Number (also called L/N or S/N or F/N) 546; Aircraft Manufacture Date 06 Nov 1989; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNT; Aircraft Construction Number (also called L/N or S/N or F/N) 546; Aircraft Manufacture Date 06 Nov 1989; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNU; Aircraft Construction Number (also called L/N or S/N or F/N) 608; Aircraft Manufacture Date 10 Apr 1991; Aircraft Model A300B4-605R; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNU; Aircraft Construction Number (also called L/N or S/N or F/N) 608; Aircraft Manufacture Date 10 Apr 1991; Aircraft Model A300B4-605R; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNV; Aircraft Construction Number (also called L/N or S/N or F/N) 567; Aircraft Manufacture Date 03 Jan 1991; Aircraft Model A310-304; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNV; Aircraft Construction Number (also called L/N or S/N or F/N) 567; Aircraft Manufacture Date 03 Jan 1991; Aircraft Model A310-304; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MNX; Aircraft Construction Number (also called L/N or S/N or F/N) 564; Aircraft Manufacture Date 22 Nov 1990; Aircraft Model A310-304; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNX; Aircraft Construction Number (also called L/N or S/N or F/N) 564; Aircraft Manufacture Date 22 Nov 1990; Aircraft Model A310-304; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MOA; Aircraft Construction Number (also called L/N or S/N or F/N) 216; Aircraft Manufacture Date 18 Feb 1993; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3216 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MOA; Aircraft Construction Number (also called L/N or S/N or F/N) 216; Aircraft Manufacture Date 18 Feb 1993; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3216; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MOB; Aircraft Construction Number (also called L/N or S/N or F/N) 212; Aircraft Manufacture Date 31 Jul 1992; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3212 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MOB; Aircraft Construction Number (also called L/N or S/N or F/N) 212; Aircraft Manufacture Date 31 Jul 1992; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3212; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MOC; Aircraft Construction Number (also called L/N or S/N or F/N) 158; Aircraft Manufacture Date 18 May 1990; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3158 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MOC; Aircraft Construction Number (also called L/N or S/N or F/N) 158; Aircraft Manufacture Date 18 May 1990; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3158; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MOD; Aircraft Manufacture Date 12 Nov 1990; Aircraft Model BAe 146-300; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3162; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MOD; Aircraft Manufacture Date 12 Nov 1990; Aircraft Model BAe 146-300; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3162; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MOE; Aircraft Construction Number (also called L/N or S/N or F/N) 129; Aircraft Manufacture Date 24 May 1989; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3129 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MOE; Aircraft Construction Number (also called L/N or S/N or F/N) 129; Aircraft Manufacture Date 24 May 1989; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3129; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MOF; Aircraft Construction Number (also called L/N or S/N or F/N) 149; Aircraft Manufacture Date 19 Dec 1989; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3149 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MOF; Aircraft Construction Number (also called L/N or S/N or F/N) 149; Aircraft Manufacture Date 19 Dec 1989; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3149; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MOG; Aircraft Construction Number (also called L/N or S/N or F/N) 165; Aircraft Manufacture Date 12 May 1990; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3165 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MOG; Aircraft Construction Number (also called L/N or S/N or F/N) 165; Aircraft Manufacture Date 12 May 1990; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3165; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MOM; Aircraft Manufacture Date 12 May 1990; Aircraft Model BAe 146-300; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3165; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MOM; Aircraft Manufacture Date 12 May 1990; Aircraft Model BAe 146-300; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3165; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MOP; Aircraft Manufacture Date 14 Mar 1995; Aircraft Model BAe RJ85; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2257; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MOP; Aircraft Manufacture Date 14 Mar 1995; Aircraft Model BAe RJ85; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2257; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MOQ; Aircraft Manufacture Date 24 Mar 1995; Aircraft Model BAe RJ85; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2261; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MOQ; Aircraft Manufacture Date 24 Mar 1995; Aircraft Model BAe RJ85; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2261; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MOR; Aircraft Manufacture Date 20 Nov 2001; Aircraft Model BAe RJ85; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2392; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MOR; Aircraft Manufacture Date 20 Nov 2001; Aircraft Model BAe RJ85; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2392; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-MOS; Aircraft Manufacture Date 15 Mar 1999; Aircraft Model BAe RJ85; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2347; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MOS; Aircraft Manufacture Date 15 Mar 1999; Aircraft Model BAe RJ85; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2347; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EP-VIP; Aircraft Construction Number (also called L/N or S/N or F/N) 499; Aircraft Manufacture Date 20 Apr 1989; Aircraft Model A310-304; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-VIP; Aircraft Construction Number (also called L/N or S/N or F/N) 499; Aircraft Manufacture Date 20 Apr 1989; Aircraft Model A310-304; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EX-301; Aircraft Construction Number (also called L/N or S/N or F/N) 524; Aircraft Manufacture Date 27 Sep 1989; Aircraft Model A310-304; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EX-301; Aircraft Construction Number (also called L/N or S/N or F/N) 524; Aircraft Manufacture Date 27 Sep 1989; Aircraft Model A310-304; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

EX-35011; Aircraft Construction Number (also called L/N or S/N or F/N) 838; Aircraft Manufacture Date 28 Aug 2002; Aircraft Model A300B4-622R; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EX-35011; Aircraft Construction Number (also called L/N or S/N or F/N) 838; Aircraft Manufacture Date 28 Aug 2002; Aircraft Model A300B4-622R; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

F-OJHH; Aircraft Construction Number (also called L/N or S/N or F/N) 586; Aircraft Manufacture Date 29 Mar 1991; Aircraft Model A310-304; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- F-OJHH; Aircraft Construction Number (also called L/N or S/N or F/N) 586; Aircraft Manufacture Date 29 Mar 1991; Aircraft Model A310-304; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

F-OJHI; Aircraft Construction Number (also called L/N or S/N or F/N) 537; Aircraft Manufacture Date 19 Jan 1990; Aircraft Model A310-304; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- F-OJHI; Aircraft Construction Number (also called L/N or S/N or F/N) 537; Aircraft Manufacture Date 19 Jan 1990; Aircraft Model A310-304; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

MAHAN AIR (a.k.a. MAHAN AIR CO.), No. 21, Mahan Air Tower, Azadegan Street, Jenah Expressway, Beginning of Sheykh Fazlollah Exp. Way, First of Karaj High Way, Tehran, Tehran 1481655761, Iran; Mahan Air Tower, 21st Floor, Azadeghan Street, Karaj Highway, P.O. Box 14515-411, Tehran, Tehran, Iran; Mahan Air Tower, Azadegan St., Karaj Highway, P.O. Box 411-14515, Tehran, Tehran 1481655761, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IFSR]. -to- MAHAN AIR (a.k.a. MAHAN AIR CO.), No. 21, Mahan Air Tower, Azadegan Street, Jenah Expressway, Beginning of Sheykh Fazlollah Exp. Way, First of Karaj High Way, Tehran, Tehran 1481655761, Iran; Mahan Air Tower, 21st Floor, Azadeghan Street, Karaj Highway, P.O. Box 14515-411, Tehran, Tehran, Iran; Mahan Air Tower, Azadegan St., Karaj Highway, P.O. Box 411-14515, Tehran, Tehran 1481655761, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [NPWMD] [IFSR].

MSN 164; Aircraft Manufacture Date 1997; Aircraft Model Airbus A340-313X; Previous Aircraft Tail Number G-VAIR; Aircraft Manufacturer’s Serial Number (MSN) 164; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 164; Aircraft Manufacture Date 1997; Aircraft Model Airbus A340-313X; Previous Aircraft Tail Number G-VAIR; Aircraft Manufacturer’s Serial Number (MSN) 164; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

MSN 371; Aircraft Manufacture Date 2001; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAC; Aircraft Manufacturer’s Serial Number (MSN) 371; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 371; Aircraft Manufacture Date 2001; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAC; Aircraft Manufacturer’s Serial Number (MSN) 371; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

MSN 376; Aircraft Manufacture Date 2001; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAB; Aircraft Manufacturer’s Serial Number (MSN) 376; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 376; Aircraft Manufacture Date 2001; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAB; Aircraft Manufacturer’s Serial Number (MSN) 376; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

MSN 383; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAA; Aircraft Manufacturer’s Serial Number (MSN) 383; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 383; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAA; Aircraft Manufacturer’s Serial Number (MSN) 383; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

MSN 391; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-642; Aircraft Manufacturer’s Serial Number (MSN) 391; Aircraft Tail Number EP-MMH; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 391; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-642; Aircraft Manufacturer’s Serial Number (MSN) 391; Aircraft Tail Number EP-MMH; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

MSN 416; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAD; Aircraft Manufacturer’s Serial Number (MSN) 416; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 416; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAD; Aircraft Manufacturer’s Serial Number (MSN) 416; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

MSN 449; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAE; Aircraft Manufacturer’s Serial Number (MSN) 449; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 449; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAE; Aircraft Manufacturer’s Serial Number (MSN) 449; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

MSN 550; Aircraft Manufacture Date 1995; Aircraft Model Airbus A321-131; Previous Aircraft Tail Number 2-WGLP; Aircraft Manufacturer’s Serial Number (MSN) 550; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 550; Aircraft Manufacture Date 1995; Aircraft Model Airbus A321-131; Previous Aircraft Tail Number 2-WGLP; Aircraft Manufacturer’s Serial Number (MSN) 550; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

MSN 615; Aircraft Manufacture Date 2004; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number G-VSSH; Aircraft Manufacturer’s Serial Number (MSN) 615; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 615; Aircraft Manufacture Date 2004; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number G-VSSH; Aircraft Manufacturer’s Serial Number (MSN) 615; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR).

UR-CJW; Aircraft Construction Number (also called L/N or S/N or F/N) 358; Aircraft Manufacture Date 12 Sep 1999; Aircraft Model BAe-146 Avro RJ100; Aircraft Manufacturer’s Serial Number (MSN) 3358 (aircraft) [SDGT] [IFSR]. -to- UR-CJW; Aircraft Construction Number (also called L/N or S/N or F/N) 358; Aircraft Manufacture Date 12 Sep 1999; Aircraft Model BAe-146 Avro RJ100; Aircraft Manufacturer’s Serial Number (MSN) 3358; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR].

UR-CKF; Aircraft Construction Number (also called L/N or S/N or F/N) 341; Aircraft Manufacture Date 20 Dec 1998; Aircraft Model BAe-146 Avro RJ100; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3341 (aircraft) [SDGT] [IFSR]. -to- UR-CKF; Aircraft Construction Number (also called L/N or S/N or F/N) 341; Aircraft Manufacture Date 20 Dec 1998; Aircraft Model BAe-146 Avro RJ100; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3341; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR].

UR-CKG; Aircraft Construction Number (also called L/N or S/N or F/N) 362; Aircraft Manufacture Date 16 Nov 1999; Aircraft Model BAe-146 Avro RJ100; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3362 (aircraft) [SDGT] [IFSR]. -to- UR-CKG; Aircraft Construction Number (also called L/N or S/N or F/N) 362; Aircraft Manufacture Date 16 Nov 1999; Aircraft Model BAe-146 Avro RJ100; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3362; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR].

UR-CKJ; Aircraft Construction Number (also called L/N or S/N or F/N) 343; Aircraft Manufacture Date 04 Sep 1999; Aircraft Model BAe-146 Avro RJ100; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3343 (aircraft) [SDGT] [IFSR]. -to- UR-CKJ; Aircraft Construction Number (also called L/N or S/N or F/N) 343; Aircraft Manufacture Date 04 Sep 1999; Aircraft Model BAe-146 Avro RJ100; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3343; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR].

UR-CKY; Aircraft Construction Number (also called L/N or S/N or F/N) 146; Aircraft Manufacture Date 08 Jan 1990; Aircraft Model BAe-146 Avro RJ100; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3146 (aircraft) [SDGT] [IFSR]. -to- UR-CKY; Aircraft Construction Number (also called L/N or S/N or F/N) 146; Aircraft Manufacture Date 08 Jan 1990; Aircraft Model BAe-146 Avro RJ100; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3146; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR].

And, finally, it issued the following 2 new Frequently Asked Questions (FAQs):

810. On December 11, 2019, the State Department announced that it would designate the Islamic Republic of Iran Shipping Lines (IRISL) and E-Sail Shipping Limited (“E-Sail”) under Executive Order (E.O.) 13382, effective June 8, 2020. IRISL and E-Sail are already listed on the SDN List. What will be the impact of the State Department’s designation of these entities under E.O. 13382?

On November 5, 2018, OFAC identified IRISL and E-Sail on the SDN List with the [IRAN] tag to indicate that they are entities meeting the definition of the Government of Iran whose property and interests in property are blocked pursuant to E.O. 13599.

Following their designation by the State Department under E.O. 13382 on June 8, 2020, OFAC will add the [NPWMD] and [IFSR] tags to the entries for IRISL and E-Sail on the SDN List. As a result, transactions by U.S. persons or within (or transiting) the United States involving IRISL and E-Sail will be subject to the prohibitions in the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544 (WMDPSR), in addition to the prohibitions in E.O. 13599 implemented through the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR). Non-U.S. persons that knowingly engage in certain transactions with IRISL or E-Sail risk exposure to sanctions under additional authorities. [12-11-2019]

811. Can I ship agricultural commodities, food, medicine, and medical devices to Iran via IRISL or E-Sail on or after June 8, 2020?

The United States maintains broad authorizations and exceptions under U.S. sanctions that allow for the sale of agricultural commodities, food, medicine, and medical devices to Iran by U.S. and non-U.S. persons (see, e.g., FAQ 637). However, these authorizations and exceptions generally do not apply to transactions with persons designated pursuant to E.O. 13382.

Following the designations of IRISL and E-Sail under E.O. 13382 on June 8, 2020, transactions by U.S. persons involving IRISL or E-Sail will be subject to the prohibitions in the WMDPSR, in addition to the prohibitions in the ITSR. This means that, effective June 8, 2020, unless authorized under the WMDPSR or exempt, U.S. persons will be prohibited from engaging in transactions involving IRISL or E-Sail, including transactions for the sale of agricultural commodities, food, medicine, or medical devices by U.S. persons or from the United States that are authorized under the general licenses set forth in, or specifically licensed pursuant to, sections 560.530, 560.532, or 560.533 of the ITSR.

In addition, non-U.S. persons that knowingly engage in certain transactions with IRISL or E-Sail, even for the sale to Iran of agricultural commodities, food, medicine, or medical devices, risk exposure to sanctions under additional authorities.

To avoid sanctions risks, U.S. and non-U.S. persons should ensure that transactions for the sale of agricultural commodities, food, medicine, or medical devices involving IRISL or E-Sail are concluded no later than June 8, 2020, when the designations of IRISL and E-Sail pursuant to E.O. 13382 come into effect. [12-11-2019]

Personally, Mr. Watchlist would like more detail on FAQ 810 – what does “risk exposure under additional authorities” mean in a practical sense?

Links:

OFAC Notice

New FAQs

↧

December 12, 2019: OFAC adds to Nicaragua sanctions

December 13, 2019, 6:20 am

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On Thursday, OFAC added the following person:

ORTEGA MURILLO, Rafael Antonio (a.k.a. “ORTEGA, Payo”), KM 13 Carretera Masaya, Managua, Nicaragua; DOB 09 Dec 1968; POB Managua, Nicaragua; nationality Nicaragua; Gender Male; Passport A00000204 (Nicaragua) issued 06 Aug 2012 expires 06 Aug 2022; National ID No. 0010912680053D (Nicaragua) (individual) [NICARAGUA].

and entities:

DISTRIBUIDORA NICARAGUENSE DE PETROLEO, S.A. (a.k.a. DNP PETRONIC; a.k.a. DNP-PETRONIC; a.k.a. NICARAGUAN PETROLEUM DISTRIBUTOR; a.k.a. “DNP”; a.k.a. “DNP S.A.”), Ofiplaza El Retiro Edificio 8, Segundo Piso, Managua, Nicaragua; Rotonda El Gueguense 2, Managua, Nicaragua; Website http://www.dnppetronic.com.ni; Email Address dnp@dnp.com.ni; RUC # J0310000005010 (Nicaragua) [NICARAGUA].

INVERSIONES ZANZIBAR SOCIEDAD ANONIMA (a.k.a. INVERSIONES ZANZIBAR), De la Estatua Montoya 2 Cuadras Arriba 1/2 Cuadras al Sur, Managua, Nicaragua; RUC # J0310000146314 (Nicaragua) [NICARAGUA].

SERVICIO DE PROTECCION Y VIGILANCIA S.A. (a.k.a. “EL GOLIAT”), De Los Semaforos De Seminole, 3 Cuadras al Sur, 2 Cuadras Arriba, 1 Cuadra al Sur, Casa #326, Managua, Nicaragua; Website http://www.elgoliat.com.ni/; Email Address ventas1@elgoliat.com.ni; alt. Email Address facturacion@elgoliat.com.ni; RUC # J0310000119627 (Nicaragua) [NICARAGUA].

to its Nicaragua-related sanctions program.

And the State Department issued a press release:

The United States Takes Action Against the Ortega Regime in Nicaragua

PRESS STATEMENT

MICHAEL R. POMPEO, SECRETARY OF STATE

DECEMBER 12, 2019

Today, the United States announces new financial sanctions against Daniel Ortega’s son Rafael Ortega and three Nicaraguan companies. This new action furthers the United States’ unwavering commitment to use all economic and diplomatic tools to hold the government of Daniel Ortega accountable for acts of corruption and unconscionable human rights violations, and to support the Nicaraguan people’s struggle for a return to democracy.

Today’s action, pursuant to Executive Order 13851 (“Blocking Property of Certain Persons Contributing to the Situation in Nicaragua”), freezes their U.S. assets and more generally prohibits U.S. persons from conducting transactions with Rafael Ortega, Inversiones Zanzibar, Servicio De Proteccion Y Vigilancia, and DNP. Rafael Ortega is a key money manager for the Ortega family, working alongside the previously sanctioned Vice President of Nicaragua and First Lady Rosario Murillo. Rafael Ortega uses at least two companies under his control, Inversiones Zanzibar, S.A and Servicio De Proteccion Y Vigilancia, S.A., to generate profits, launder money, and gain preferential access to markets for the Ortega regime. He uses Inversiones Zanzibar to obscure the transfer of profits from Distribuidor Nicaraguense de Petroleo, also designated today, and as a front company to procure fuel stations in an attempt to obscure DNP’s ownership of such fuel stations. Servicio De Proteccion Y Vigilancia is a security firm which has received millions in Nicaraguan government contracts. DNP is a chain of gas stations controlled by the Ortega family. DNP was purchased with public money and then transferred to the Ortega family, and it benefits from non-competitive contracts with government institutions.

The United States urges the Ortega regime to resume dialogue with the opposition and restore democracy in the country, thereby fulfilling its obligations under the Inter-American Democratic Charter. Nicaragua’s painful political crisis can only be resolved through free and fair elections that credibly reflect the will of the Nicaraguan people and with full respect for their human rights and fundamental freedoms.

Links:

OFAC Notice

State Department Press Release

↧

One way to avoid OFAC enforcement: go out of business

December 13, 2019, 7:30 am

≫ Next: OFAC adds counter terrorism designations (and FAQs), and removes cyber designations

≪ Previous: December 12, 2019: OFAC adds to Nicaragua sanctions

OFAC Issues a Finding of Violation to Aero Sky Aircraft Maintenance, Inc. for Violations of the Global Terrorism Sanctions Regulations: OFAC has issued a Finding of Violation to Aero Sky Aircraft Maintenance, Inc. (“Aero Sky”), a Texas company located in San Antonio, that negotiated and entered into a contract and contingent contract with Mahan Air in violation of the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (GTSR). On October 12, 2011, OFAC designated Mahan Air, an Iranian commercial airline company, pursuant to Executive Order 13224 for providing financial, material, and technological support to the Islamic Revolutionary Guard Corps-Qods Force. Accordingly, Mahan Air is identified on OFAC’s List of Specially Designated Nationals and Blocked Persons (the “SDN List”). OFAC determined that in 2016, Aero Sky violated § 594.201(a) of the GTSR by dealing in the property and interests in property of Mahan Air when Aero Sky negotiated and entered into a contract and a second contingent contract with Mahan Air (hereinafter referred to as the “Violations”).

Aero Sky subsequently entered into bankruptcy proceedings and has since dissolved.

Aero’s Sky dissolution, OFAC believes the facts presented in this matter would have justified a strong civil monetary penalty.

So, what did Aero Sky do?
On December 19, 2016, after multiple rounds of negotiations with Mahan Air representatives, Aero Sky entered into Memorandum of Understanding (MOU) with Mahan Air and two other parties. The MOU called for the parties to, among other things, make reasonable efforts to collaborate in order to provide future non-exclusive maintenance and repair services to Mahan Air and to enter into a joint venture agreement. The MOU also included an appendix that stated that the MOU was contingent, in part, upon Mahan Air being removed from OFAC’s SDN List.

Aero Sky was aware that Mahan Air was an entity identified on the SDN List. Prior to the

negotiations of, and entry into, the contingent contract with Mahan Air, Aero Sky consulted legal

counsel, who reviewed OFAC’s website and determined that Mahan Air was listed as a Specially

Designated Global Terrorist on OFAC’s SDN List. Nonetheless, Aero Sky mistakenly

determined that its negotiation of, and entry into, a contingent contract with Mahan Air was

authorized under the scope of Iran General License I (“GL I”), Authorizing Certain Transactions

Related to the Negotiation of, and Entry into, Contingent Contracts for Activities Eligible for

Authorization Under the Statement of Licensing Policy for Activities Related to the Export or Re-export to Iran of Commercial Passenger Aircraft and Related Parts and Services

At the relevant time, GL I authorized certain transactions related to the negotiation of, and entry into, contingent contracts for activities eligible for authorization under the then-Joint Comprehensive Plan of Action Statement of Licensing Policy. However, GL I explicitly and specifically excluded transactions and dealings with any person whose property or interests in property were blocked pursuant to any part of 31 C.F.R. chapter V other than part 560. At all times during which Aero Sky engaged in the conduct associated with the Violations, Mahan Air was designated (and continues to be designated) pursuant to Executive Order 13224 and the GTSR—a part of 31 C.F.R. chapter V other than part 560.

GL I did not authorize Aero Sky to enter into negotiations and a contract or contingent contract with Mahan Air. Therefore, Aero Sky dealt with a person whose property or property interests were blocked without authorization from OFAC in violation of § 594.201(a) of the GTSR. OFAC determined that Aero Sky did not voluntarily self-disclose the Violations.

Here are the aggravating factors:

(1) Aero Sky engaged in a reckless violation of the law by failing to exercise a minimal degree of caution or care by negotiating and entering into a contingent contract with an entity on the SDN List;

(2) A senior Aero Sky executive had actual knowledge of, and participated in, the conduct that led to the Violations; and

(3) Aero Sky undermined the policy objectives of the GTSR by dealing in blocked property or property interests of a high-profile entity identified on the SDN List— Mahan Air. Mahan Air was designated in 2011, approximately five years prior to the Violations. As OFAC has publicly documented on numerous occasions, Mahan Air supports terrorism by providing, among other things, financial, material and technological support to the Islamic Revolutionary Guard Corps-Qods Force, and support to the Iranian government’s destabilizing activity in the Middle East.

and mitigating factors:

(1) Aero Sky has not been subject to a Finding of Violation or penalty notice from OFAC in the five years preceding the date of the transaction giving rise to the Violations; and

(2) Aero Sky was a small company in poor financial condition that dissolved after the violations.

And OFAC’s takeaways for the public:

This enforcement action demonstrates that any individuals or entities engaging in dealings or transactions with persons, regions, or countries subject to U.S. economic and trade sanctions in accordance with a specific or general license issued by OFAC should ensure they carefully review, and fully comply with, all of the terms and conditions of those licenses. The execution of a contract or contingent contract by a person subject to OFAC’s jurisdiction with a person whose property and property interests are blocked is prohibited, unless authorized by OFAC or exempt by law. Furthermore, this enforcement action demonstrates the U.S. government’s commitment to enforcing sanctions in response to prohibited dealings with designated Iranian airlines, such as Mahan Air. For example, on July 23, 2019, OFAC issued an Iran-Related Civil Aviation Industry Advisory to warn of deceptive practices employed by Iran with respect to aviation matters.

As noted in OFAC’s A Framework for Compliance Commitments, issued in May 2019, risks in sanctions compliance are potential threats or vulnerabilities that, if ignored or not properly handled, can lead to violations of OFAC’s regulations and negatively affect an organization’s reputation and business. U.S. companies can mitigate sanctions risk by conducting risk assessments and exercising caution when doing business with entities that are affiliated with, or known to transact with, OFAC-sanctioned persons or jurisdictions, or that otherwise pose high risks due to their joint ventures, affiliates, subsidiaries, customers, suppliers, geographic location, or the products and services they offer.

Link:

OFAC Enforcement Information

↧

OFAC adds counter terrorism designations (and FAQs), and removes cyber designations

December 13, 2019, 8:51 am

≫ Next: OFAC adds 2 people to South Sudan sanctions

≪ Previous: One way to avoid OFAC enforcement: go out of business

Today OFAC added the following persons:

AHMAD, Nazem Said (a.k.a. AHMAD, Nazem Ali; a.k.a. AHMAD, Nazem Saeed; a.k.a. AHMAD, Nazim; a.k.a. AHMAD, Nazim Sa’id; a.k.a. AHMAD, Nizam Saed; a.k.a. AHMED, Nazem Said; a.k.a. AHMED, Nazem Saied), Mteferraa From Es Semrlnd, Beirut, Lebanon; DOB 05 Jan 1965; POB Sierra Leone; nationality Lebanon; citizen Belgium; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Gender Male (individual) [SDGT] (Linked To: HIZBALLAH).

ASSI, Saleh (a.k.a. ‘ASI, Salih ‘Ali; a.k.a. ASSI, Salah; a.k.a. ASSI, Saleh Ali; a.k.a. ASSI, Salih), Congo, Democratic Republic of the; Etage 5 (5th Floor), 3 Avenue Bosquet, Paris 27007, France; Bashoura, Beirut, Lebanon; Immeuble Verdun 750, 5E Etage-Rue Rachid Karame Verdun, Beyrouth, Lebanon; DOB 14 May 1960; citizen France; Gender Male; Passport 04FE50421 (France) (individual) [SDGT] (Linked To: TABAJA, Adham Husayn).

SAAB, Tony (a.k.a. SA’B, Tony Boutros; a.k.a. SA’B, Tony Butrus), Tannourine Tahta, Batroun, Lebanon; DOB 20 May 1977; Gender Male (individual) [SDGT] (Linked To: ASSI, Saleh).

and entities:

AL YUMUN REAL ESTATE COMPANY SAL, Beirut, Lebanon; Commercial Registry Number 48642 (Lebanon) [SDGT] (Linked To: ASSI, Saleh).

ARAMOUN 1506 SAL, Jnah, Adnan Al Hakim Street, Al Wazeer Building, First Floor, Real Estate No. 3673, Beirut, Lebanon; Commercial Registry Number 1013408(Lebanon) [SDGT] (Linked To: AHMAD, Nazem Said).

BEIRUT DIAM SAL (a.k.a. BEIRUT DIAM COMPANY SAL), Downtown Beirut, Solidere, Property No. 1479 of Marfa Real Estate, Block A, 4th Floor, Beirut, Lebanon; Commercial Registry Number 1005283 (Lebanon) [SDGT] (Linked To: AHMAD, Nazem Said).

BEIRUT GEM SAL (a.k.a. BEIRUT GM SAL), Downtown Beirut, Solidere, Property No. 1479 of Marfa Real Estate, Block A, 4th Floor, Beirut, Lebanon; Commercial Registry Number 1005284 (Lebanon) [SDGT] (Linked To: AHMAD, Nazem Said).

BEIRUT TRADE SAL, Maarad Street, Solidere King, Property 200, Harbor, Beirut, Lebanon; Building 200, Maarad Street, Beirut, Lebanon; Commercial Registry Number 1004271 (Lebanon) [SDGT] (Linked To: AHMAD, Nazem Said).

BLUE STAR DIAMOND SAL – OFFSHORE, Ramla Al Bayda, Al Bizri Street, Beirut, Lebanon; Commercial Registry Number 1800235 (Lebanon) [SDGT] (Linked To: AHMAD, Nazem Said).

DAMOUR 850 SAL, Jnah, Adnan Al Hakim Street, Minister Building, First Floor, Beirut, Lebanon; Commercial Registry Number 1013407 (Lebanon) [SDGT] (Linked To: AHMAD, Nazem Said).

DEBBIYE 143 SAL (a.k.a. AL DIBIYA 143 SAL), Adnane Al Hakim Street, Al-Wazeer Building, First Floor, Building No. 3673, Msaytbeh, Beirut, Lebanon; Commercial Registry Number 1013410 (Lebanon) [SDGT] (Linked To: AHMAD, Nazem Said).

GEBAA 2480 SAL (a.k.a. JEBAA 2480 SAL), Adnan Al Hakim Street, Al Wazeer Building, First Floor, Building No. 3672, Msaytbeh, Beirut, Lebanon; Commercial Registry Number 1013406 (Lebanon) [SDGT] (Linked To: AHMAD, Nazem Said).

INTER ALIMENT SAL OFF-SHORE (a.k.a. INTERALIMENT OFFSHORE COMPANY), Verdun 732 Center 3377/74 Mousseitbeh, Dar El-Fatwa Sector, Rachid Karame Sreet, Beirut, Lebanon; Verdun – Center, 730, Section 74 of the property 3377, Area Msaytbeh Real Estate – the fifth floor, Beirut, Lebanon; 732 Center, 5th Floor, Verdun Street, Beirut, Lebanon; D-U-N-S Number 557757412; Phone Number 9611797101; Registration ID 1239305; Commercial Registry Number 1801267 (Lebanon) [SDGT] (Linked To: ASSI, Saleh).

MINOCONGO (a.k.a. MINO CONGO; a.k.a. MINOTERIE DU CONGO SPRL), Avenue Konda-Konda No 2, Commune De Ngaliema, Kinshasa 180, Congo, Democratic Republic of the; D-U-N-S Number 850461914 [SDGT] (Linked To: ASSI, Saleh).

MONTECARLO BEACH SAL, Beirut, Lebanon; Commercial Registry Number 44925 (Lebanon) [SDGT] (Linked To: AHMAD, Nazem Said).

NOUMAYRIYE 1057 SAL (a.k.a. NUMEIRIYA 1057 SAL), Adnan Al Hakim Street, Al Wazeer Building, First Floor, Building No. 3673, Msaytbeh, Beirut, Lebanon; Commercial Registry Number 1013409 (Lebanon) [SDGT] (Linked To: AHMAD, Nazem Said).

NOUR HOLDING SAL (a.k.a. NOOR HOLDING SAL), Bizri Street, Beirut, Lebanon; Commercial Registry Number 1901008 (Lebanon) [SDGT] (Linked To: AHMAD, Nazem Said).

PAIN VICTOIRE (a.k.a. PAINS VICTOIRE; a.k.a. PAN VICTOIRE; a.k.a. SOCIETE GENERAL DES PAINS SPRL; a.k.a. SOCIETE GENERALE DE PAIN; a.k.a. SOCIETE GENERALE DES PAINS), 22 Avenue Konda, Kinshasa, Congo, Democratic Republic of the; D-U-N-S Number 558023852 [SDGT] (Linked To: ASSI, Saleh).

SALASKO OFFSHORE S.A.L., Verdun, Beirut, Lebanon; Commercial Registry Number 1801152 (Lebanon) [SDGT] (Linked To: ASSI, Saleh).

TRANS GAZELLE (a.k.a. TRANS GAZELLE SPRL; a.k.a. TRANSGAZELLE), Congo, Democratic Republic of the [SDGT] (Linked To: ASSI, Saleh).

and cargo vessel:

FLYING DRAGON Pleasure Craft Malta flag; Vessel Registration Identification IMO 9752216; MMSI 248297000 (vessel) [SDGT] (Linked To: ASSI, Saleh).

to its counter terror sanctions. It also removed the following cyber-related sanctions designations:

TSAO, OOO (Cyrillic: ООО ЦАО) (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU TSENTR AVTOOBSLUZHIVANIYA), 9, per., Omski Kurgan, Kurganskaya Oblast 640000, Russia; D-U-N-S Number 68-215-4722; Tax ID No. 4501122896 (Russia); Government Gazette Number 78739479 (Russia); Registration Number 1064501172394 (Russia) [CYBER2] (Linked To: GUSEV, Denis Igorevich).

OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU TSENTR AVTOOBSLUZHIVANIYA (a.k.a. TSAO, OOO (Cyrillic: ООО ЦАО)), 9, per., Omski Kurgan, Kurganskaya Oblast 640000, Russia; D-U-N-S Number 68-215-4722; Tax ID No. 4501122896 (Russia); Government Gazette Number 78739479 (Russia); Registration Number 1064501172394 (Russia) [CYBER2] (Linked To: GUSEV, Denis Igorevich).

VERTIKAL, OOO (Cyrillic: ООО ВЕРТИКАЛЬ) (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU VERTIKAL), d. 102/1, ul. Beregovaya Kogalym, Khanty-Mansiski, Avtonomny Okrug – Yugra Okr. 628482, Russia; D-U-N-S Number 50-630-4726; Tax ID No. 8608056026 (Russia); Government Gazette Number 26149774 (Russia); Registration Number 1138608000189 (Russia) [CYBER2] (Linked To: GUSEV, Denis Igorevich).

OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU VERTIKAL (a.k.a. VERTIKAL, OOO (Cyrillic: ООО ВЕРТИКАЛЬ)), d. 102/1, ul. Beregovaya Kogalym, Khanty-Mansiski, Avtonomny Okrug – Yugra Okr. 628482, Russia; D-U-N-S Number 50-630-4726; Tax ID No. 8608056026 (Russia); Government Gazette Number 26149774 (Russia); Registration Number 1138608000189 (Russia) [CYBER2] (Linked To: GUSEV, Denis Igorevich).

YUNIKOM, OOO (Cyrillic: ООО ЮНИКОМ) (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU YUNIKOM), d. 18, ul. Tsentralnaya Kogalym, Khanty-Mansiski, Avtonomny Okrug – Yugra Okr. 628483, Russia; D-U-N-S Number 68-321-9795; Tax ID No. 8608052180 (Russia); Government Gazette Number 97396163 (Russia); Registration Number 1068608008204 (Russia) [CYBER2] (Linked To: GUSEV, Denis Igorevich).

OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU YUNIKOM (a.k.a. YUNIKOM, OOO (Cyrillic: ООО ЮНИКОМ)), d. 18, ul. Tsentralnaya Kogalym, Khanty-Mansiski, Avtonomny Okrug – Yugra Okr. 628483, Russia; D-U-N-S Number 68-321-9795; Tax ID No. 8608052180 (Russia); Government Gazette Number 97396163 (Russia); Registration Number 1068608008204 (Russia) [CYBER2] (Linked To: GUSEV, Denis Igorevich).

Finally, it issued 3 new counter terror Frequently Asked Questions (FAQs):

812. As a U.S. person, am I prohibited from engaging in transactions involving information or informational materials, including artwork, that are the property or subject to an interest in property of persons designated as Specially Designated Global Terrorists (SDGTs) under or otherwise blocked pursuant to Executive Order 13224, as amended, (E.O. 13224)?

Yes. In general, any transaction or dealing by a U.S. person in any property or interests in property of persons designated as SDGTs under or otherwise blocked pursuant to E.O. 13224 is prohibited. Such property includes artwork and other information and information materials. Certain exemptions available under the International Emergency Economic Powers Act (IEEPA) relating to personal communications, humanitarian donations, information or informational materials, and travel do not apply to transactions with SDGTs or persons otherwise blocked pursuant to E.O. 13224.

For purposes of these prohibitions, U.S. persons include all U.S. citizens and permanent resident aliens regardless of where they are located, all persons and entities within the United States, and all U.S.-incorporated entities and their foreign branches. U.S. persons who engage in prohibited transactions with SDGTs or with persons otherwise blocked pursuant to E.O. 13224 may be subject to civil or criminal penalties.

Non-U.S. persons who engage in prohibited transactions or dealings subject to U.S. jurisdiction with SDGTs or with persons otherwise blocked pursuant to E.O. 13224 may be subject to civil or criminal penalties, and may also risk being sanctioned by OFAC. Foreign financial institutions may also be subject to correspondent and payable through account sanctions if they knowingly facilitate significant transactions for or on behalf of an SDGT. [12-13-2019]

813. As a member of the art community, what are my compliance obligations with respect to Executive Order 13224, as amended?

U.S. persons (including galleries, museums, private art collectors, auction companies, and others that conduct or facilitate transactions involving artwork) must ensure that they do not engage in transactions with persons listed as Specially Designated Global Terrorists (SDGTs) on OFAC’s SDN List or with persons otherwise blocked pursuant to E.O. 13224, unless authorized by OFAC. U.S. persons should develop a tailored, risk-based compliance program, which may include sanctions list screening or other appropriate measures. An adequate compliance solution will depend on a variety of factors, including the type of business involved, and there is no single compliance program or solution suitable for every circumstance.

For purposes of these requirements, U.S. persons include all U.S. citizens and permanent resident aliens regardless of where they are located, all persons and entities within the United States, and all U.S.-incorporated entities and their foreign branches. U.S. persons who engage in prohibited transactions may be subject to civil or criminal penalties.

Non-U.S. persons who engage in prohibited transactions subject to U.S. jurisdiction with SDGTs or persons otherwise blocked pursuant to E.O. 13224 may be subject to civil or criminal penalties, and also risk being sanctioned by OFAC. Foreign financial institutions may be subject to correspondent and payable through account sanctions if they knowingly facilitate significant transactions for or on behalf of a SDGT.

The names of, and identifying information for, all individuals and entities included on OFAC’s sanctions lists may be located via OFAC’s free, online search engine at the following URL: http://sanctionssearch.ofac.treas.gov. In addition, OFAC offers text and PDF versions of these lists for manual review and a number of data file versions of its lists that are designed to facilitate automated screening. Depending on the scale, sophistication, and risk profile of your business, you may consider one of the numerous commercially available screening software packages. [12-13-2019]

814. I am currently in possession of artwork in which a Specially Designated Global Terrorist (SDGT) has an interest. What should I do?

Once it has been determined that you or your institution is holding or is in possession of artwork that is the property of an SDGT or a person otherwise blocked pursuant to E.O. 13224, or in which such a person has an interest, you or your institution must ensure that access to that artwork is denied to the SDGT or blocked person and that your institution complies with OFAC regulations related to blocked assets, including restrictions on the sale or transfer of the artwork to third parties. Pursuant to 31 CFR section 501.603, blocked property, physical or financial, must be reported to OFAC within 10 business days; U.S. persons must also comply with all other applicable reporting obligations. See FAQs 49 and 50. Questions about whether a transaction should be blocked should be directed to OFAC at 202-622-2490 or ofac_feedback@treasury.gov. [12-13-2019]

Links:

OFAC Notice

New FAQs

↧

OFAC adds 2 people to South Sudan sanctions

December 16, 2019, 8:48 am

≫ Next: December 17, 2019: OFAC publishes 1QFY2019 TSRA Licensing Report

≪ Previous: OFAC adds counter terrorism designations (and FAQs), and removes cyber designations

Earlier today, OFAC added the following 2 individuals: to their South Sudan-related sanctions program:

JUUK, Kuol Manyang (a.k.a. JUUK CHAW, Kuol Manyang), Juba, South Sudan; DOB 01 Jan 1945; POB Mathiang Village, South Sudan; nationality South Sudan; Gender Male; Passport D00002510 (South Sudan) (individual) [SOUTH SUDAN].

LOMURO, Martin Elia (a.k.a. LOMORO, Martin Elia; a.k.a. LOMORO, Martin Elias), Juba, South Sudan; DOB 28 Dec 1957; citizen South Sudan; alt. citizen Sudan; Gender Male; Passport D00002571 (South Sudan); alt. Passport D00009058 (Sudan) (individual) [SOUTH SUDAN].

Link:

OFAC Notice

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