Here is OFAC’s summary:

From October 1 through December 31, 2018, OFAC’s Licensing Division received a total of 36 applications pursuant to Section 906(a)(1) of the TSRA. During this period, OFAC issued a total of 19 licensing determinations,2 of which 11 were for cases received in this quarter. OFAC issued 3 licenses, 2 license amendments, 4 “return-without-action” letters, 1 denial letter, and 9 general license guidance letters in this quarter. Of the total licenses issued, 3 involved products for Iran and 0 for Sudan.

Of the 36 license applications (in a handy chart that doesn’t cut and paste well), 20 were for Medical Devices (of which 2 licenses were issued and 1 amendment issued), 10 were for Medicine (1 license issued), and 6 were for Agricultural Commodities (1 amendment issued, 1 application denied). Of the applications, only 2 were for Sudan (1 each for Agricultural Commodities and Medicine), and none of those were approved or denied.

While the overall processing time for all the applications was 32 days, it varied wildly, with Denial Letters taking 64 days on averages, and Licenses taking 74 days on average – and with Amendments taking only 5 days.

Links:

OFAC Notice

1QFY2019 TSRA Report

On Wednesday, OFAC removed the following entities from the Global Magnitsky sanctions program:

but not its former sanctioned owner.

Additionally, General License 1 was amended to extend its deadline until January 8th.

Links:

OFAC Notice

General License 1A

Today, OFAC added the following 2 individuals to its Iran sanctions program:

They are both designated under the Iranian Transactions and Sanctions Regulations (ITSR), which reflects the IRAN program code, and the Iran Threat Reduction and Syria Human Rights Act of 2012, which is the IRAN-TRA program code.

Link:

OFAC Notice

List of OFAC Program codes

On Thursday, OFAC added the following persons:

and entities:

to its counter narcotics trafficking sanctions program under the Kingpin Act authorities.

Additionally, the following listings were removed from the Cuba sanctions program:

NAVIERA MARITIMA DE AROSA, S.A., Paseo de Pereda 36, Apartado 141, Santander 39004, Spain [CUBA].

and the counter narcotics program:

Also, one Kingpin Act designation was changed:

MARTINEZ LASSO, Vielka Judith; DOB 09 Nov 1967; POB El Higo, San Carlos, Panama; Cedula No. 8-283-646 (Panama) (individual) [SDNTK] (Linked To: THEA HOLDING & CO., INC.; Linked To: INVERSIONES OMEGA INTERNACIONAL S.A.; Linked To: GCH & SONS CO., INC.; Linked To: EURO FINANCING, CORP.; Linked To: EUROCAMBIO INVESTMENT S.A.; Linked To: INVERSIONES TROL PANAMA S.A.; Linked To: EUROCAMBIO, S.A.; Linked To: BEAUTY STATION, S.A.). -to- MARTINEZ LASSO, Vielka Judith; DOB 09 Nov 1967; POB El Higo, San Carlos, Panama; Cedula No. 8-283-646 (Panama) (individual) [SDNTK] (Linked To: INVERSIONES OMEGA INTERNACIONAL S.A.; Linked To: EURO FINANCING, CORP.; Linked To: EUROCAMBIO INVESTMENT S.A.; Linked To: INVERSIONES TROL PANAMA S.A.; Linked To: EUROCAMBIO, S.A.; Linked To: BEAUTY STATION, S.A.).

And the State Department issued a press release about the new designations:

Sanctions Against Guatemalan Mayor and His Drug Trafficking Organization

PRESS STATEMENT

MORGAN ORTAGUS, DEPARTMENT SPOKESPERSON

DECEMBER 19, 2019

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OFAC Notice

State Department Press Release

Yesterday, OFAC issued a new version of Iran General License K, which permits maintenance and wind-down activities involving COSCO Shipping Tanker (Dalian) Co, Ltd. The new version now expires on February 4, 2020.

Along with this, updated versions of Frequently Asked Questions 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 December 19, 2019, OFAC issued General License K-1  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. [12-19-2019]

806:

806. What types of activities are considered “maintenance” as the term is used in General License K-1?

As a general matter, the authorization for “maintenance” in General License K -1 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-1 Covered Entities”). Additionally, for the purposes of General License K-1, 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-1 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-1 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-1 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-1 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-1 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-1 could include issuing or accepting purchase orders (including for sales of fuel to General License K-1 Entities) and making or receiving shipments (including undertaking new charters or voyages) that were initiated after September 25, 2019 involving General License K-1 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-1 Entities prior to September 25, 2019. Conversely, General License K-1 would not authorize purchase orders and shipments involving the General License K-1 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-1 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. [12-19-2019]

and 807:

were issued.

Links:

OFAC Notice

Iran General License K-1

Amended FAQs: 804, 806, 807

Today, OFAC added the following people:

to their Mali sanctions program.

Link:

OFAC Notice

On Friday, OFAC issued the following new Ukraine/Russia-related Frequently-Asked Question:

815. How does the U.S. government plan to implement the wind-down specified in Section 7503(d) of the National Defense Authorization Act for Fiscal Year 2020 (NDAA), also known as the Protecting Europe’s Energy Security Act of 2019?   

Upon signature by the President on December 20, 2019, the provisions of Section 7503 of the NDAA immediately became effective.  In order to comply with the wind-down provisions of Section 7503(d) of the NDAA, involved parties that have knowingly sold, leased, or provided vessels that are engaged in pipe laying at depths of 100 feet or more below sea level for the construction of Nord Stream 2 or Turkstream must ensure that such vessels immediately cease construction-related activity.  Notwithstanding the above, good-faith wind-down exceptions may be made for the safety of the pipeline or safety and care of the crew aboard the vessel, the protection of human life, or maintenance to avoid any environmental or other significant damage, as further described in Section 7503(e). [12-20-2019]

Link:

OFAC Notice

Simply put, Chubb Corporation merged with ACE Limited, and one of ACE’s subsidiaries was subject to US jurisdiction (because one of its parents was incorporated in the US). And that subsidiary apparently violated the Cuban Assets Control Regulations(CACR) 20,291 times. The huge bulk of these were premium payments for Cuba-related travel insurance, with a small number (less than 100) claims related to Cuban travel.

Notably, the enforcement action notes:

The apparent violations appear to have been caused by ACE’s misunderstanding of the applicability of U.S. sanctions on Cuba with respect to this activity.

It also notes that the insurance policies did not include a “sanctions exclusionary clause, which is often inserted in global insurance policies as an explicit exclusion for risks that would violate U.S. sanctions law.”

ACE voluntarily self-disclosed the violations, which were deemed non-egregious. The base penalty for all these violations was $183,923.52, which then resulted in a final settlement amount of $66,212.

Here were the aggravating factors:

(1) ACE failed to implement adequate internal controls, including failing to use sanctions exclusionary clauses in its global policies, to mitigate the sanctions compliance risks inherent in issuing insurance policies that covered Cuba-related travel;

(2) Certain ACE Europe’s business leaders and their regional legal and compliance team had knowledge of the issuance of policies covering travel to Cuba and reason to know of the U.S. sanctions against Cuba but failed to insert sanctions exclusionary clauses based on its erroneous legal conclusions relating to the E.U.’s blocking regulation and the de minimis exposure presented by the Cuba policies;

(3) The activity described resulted from a pattern or practice spanning several years;

(4) ACE conferred economic benefit to U.S. sanctioned parties, and caused harm to the integrity of

U.S. sanctions programs, including their associated policy objectives by enabling and supporting individuals’ ability to travel to Cuba through the provision of travel insurance coverages, and the payment of claims under the coverages;

(5) ACE is a large and commercially sophisticated financial institution.

and mitigating factors:

(1) Many of the transactions at issue in this case would have been authorized by general license had they occurred on or after January 16, 2015, the date on which OFAC issued certain amendments to the CACR that authorized certain Cuba travel-related insurance activities;

(2) ACE has not received a penalty notice or Finding of Violation from OFAC in the five years preceding the date of the earliest transaction giving rise to the apparent violations;

(3) ACE cooperated with OFAC’s investigation into these apparent violations, including by voluntarily self-disclosing the apparent violations to OFAC, conducting a transaction review, responding to OFAC’s requests for information, and entering into a statute of limitations tolling agreement with multiple extensions;

(4) The compliance deficiency that enabled the apparent violations appears to have been concentrated within a single ACE operating entity, and does not appear to have been widespread throughout the overall ACE organizational structure;

(5) In response to the apparent violations (which ACE management was alerted to after ACE Europe personnel raised questions following a sanctions compliance training), ACE represented that it has implemented remedial actions and instituted numerous compliance policy, procedure and training enhancements across its global operations, including:

• Hiring a Global Financial Crime Risk Officer;

• Conducting a comprehensive risk assessment across the Europe, Eurasia, and Africa

regions; and

• Developing a sanctions risk assessment methodology to identify potential gaps, and to

drive future remediation work and improvements.

considered by OFAC to affect the final amount of the civil monetary penalty.

And OFAC’s lessons to be learned:

This enforcement action underscores: the applicability of U.S. sanctions to certain foreign-based entities; the importance of incorporating sanctions exclusionary clauses to mitigate potential sanctions violations; and the significance of maintaining robust internal controls and training practices designed to identify and prevent potential sanctions violations before they occur.

Link:

OFAC Enforcement Information

Allianz agreed to pay $170,535 for 6474 voluntarily self-disclosed, non-egregious apparent violations of the Cuban Asset Control Regulations (CACR), reduced from a base penalty of $270,690.90.

Here is the narrative of what Allianz did:

Between August 20, 2010 and January 15, 2015, AGR Canada fronted travel insurance policies that included occasional coverage relating to Canadian residents’ travel to Cuba. “Fronting” insurance business involves an arrangement between two or more insurance companies to allow a company to issue a policy in a jurisdiction where it is not licensed. The insurance policies fronted by AGR Canada consisted of two types of insurance policies sold to Canadian citizens and residents covered by Canadian health plans: first, insurance coverage for an individual trip that would be in effect for 30 days for the specific trip (e.g., a single trip to Cuba), and second, insurance coverage that would be in effect for a full year and provide coverage for every trip taken during that time (e.g. covering multiple trips to several countries, including one or more trips to Cuba). The travel insurance policies covered reimbursement for eligible emergency medical expenses while out of country and non-refundable expenses resulting from trip cancellation, delay, or interruption due to specified categories of events.

A Canadian underwriting manager operating separately from AGR Canada underwrote, marketed, and serviced the insurance policies. Neither the underwriting manager nor AGR Canada collected information regarding the travel destination upon policy issuance. A travel destination was only disclosed to the underwriting manager in instances where emergency medical assistance was required, a claim was submitted, or a coverage inquiry was received disclosing the destination. AGR Canada received only a quarterly summary premium and claims information. Travel destination information was not included in that summary.

Despite learning on at least one occasion during the relevant period that AGR Canada was issuing insurance policies related to travel to Cuba, this practice continued for several years without either AGR US or AGR Canada addressing its requirements to be in compliance with OFAC regulations.

The policies resulted in the processing and reimbursement of 864 Cuba-related claims totaling CAD 532,200.35 (approximately $518,092), and the collection of CAD 30,599.61 (approximately $23,289) in premiums. Despite AGR Canada’s status as a person subject to the jurisdiction of the United States as defined by section 515.329 of the CACR, 31 C.F.R. Part 515 and communications with the underwriting manager early in the relevant period that referenced Cuba-related coverage, AGR US does not appear to have taken steps or implemented adequate controls to prevent the fronting of Cuba travel policies issued during this period. AGR US did not initiate an internal investigation until 2014, which resulted in the self-disclosure.

By insuring non-Cuban travelers to Cuba, AGR Canada enabled travel to Cuba by persons that might otherwise not have traveled to the country, thereby bringing revenue and funds to Cuba, including the Cuban government that may not have otherwise flowed at a time when such activity was prohibited.

By providing this coverage, AGR Canada appears to have violated section 515.201 of the CACR, which prohibits persons subject to the jurisdiction of the United States from engaging in transactions in which Cuba or a Cuban national has an interest. The CACR were amended on January 16, 2015 to authorize pursuant to § 515.580 the issuance of global travel insurance policies that include coverage for travel to and from Cuba.

When calculating the final settlement amount, OFAC considered the following aggravating:

(1) AGR US failed to exercise a minimal degree of caution or care in allowing its Canadian branch, AGR Canada, to front travel insurance policies covering travel to Cuba for a period of almost five years;

(2) AGR US and AGR Canada failed to address or further investigate the issuance of insurance policies related to Cuba travel in response to several notifications in 2010 that constituted notice that AGR Canada was providing prohibited coverage;

(3) AGR US and AGR Canada appear to have ignored warning signs and continued this pattern of conduct for several more years;

(4) Both AGR US and AGR Canada had actual knowledge of the Cuba-related coverage as early as 2010;

(5) By fronting travel insurance policies and providing coverage to individuals traveling to Cuba, AGR Canada provided economic benefit to Cuba and caused harm to the integrity of the CACR, and their associated policy objectives; and

(6) At the time of the apparent violations, AGR US and AGR Canada did not maintain specific OFAC Compliance procedures related to the fronting of travel insurance policies.

and mitigating:

(1) It does not appear that any supervisory or managerial level staff at AGR US or AGR Canada were aware of the conduct;

(2) AGR US has not received a finding of violation or penalty notice from OFAC in the five years preceding the earliest date of the transactions giving rise to the apparent violations in this matter;

(3) In response to the apparent violations described, AGR US stated that it undertook steps to

enhance its OFAC compliance program, including the establishment of oversight processes and by hiring a full-time legal and compliance officer for AGR Canada in order to address the compliance risks posed by the branch; and

(4) AGR US cooperated with OFAC by voluntarily self-disclosing the apparent violations, entering into and extending a statute of limitations tolling agreement, and providing document productions that were well-organized. Further, AGR US facilitated OFAC’s review of the relevant information and documentation related to the investigation.

factors.

And this is the lesson OFAC believes you should take away from this enforcement action:

This enforcement action draws particular attention to the importance of risk assessments in determining which financial products can be offered by persons subject to U.S. jurisdiction in the context of OFAC-administered sanctions programs. The enforcement action also highlights the need for, and importance of, internal controls, policies, and procedures in detecting and preventing potential violations of this nature in a timely manner.

Link:

OFAC Enforcement Information

On Friday, OFAC added:

ASA’IB AHL AL-HAQ (a.k.a. AL-TAYAR AL-RISALI; a.k.a. ASA’IB AHL AL-HAQ MIN AL-IRAQ; a.k.a. ASA’IB AHL AL-HAQQ; a.k.a. ASAIB AL HAQ; a.k.a. KHAZALI NETWORK; a.k.a. KHAZALI SPECIAL GROUP; a.k.a. KHAZALI SPECIAL GROUPS NETWORK; a.k.a. LEAGUE OF THE RIGHTEOUS; a.k.a. QAZALI NETWORK; a.k.a. “AAH”; a.k.a. “THE MISSIONARY CURRENT”; a.k.a. “THE PEOPLE OF THE CAVE”), Iraq [SDGT].

to their counter terrorism sanctions, and updated the following Global Magnitsky sanctions listings:

Links:

OFAC Notice

Earlier today, OFAC issued an amended version of Venezuela General License 6 “Authorizing Certain Activities Necessary to the Wind Down of Operations or Existing Contracts with Globovision Tele C.A. or Globovision Tele CA, Corp.”. The only obvious substantive change is that it has been extended for 2 weeks, until January 21, 2020.

Links:

OFAC Notice

General License 6A

Earlier today, OFAC added:

GAI, Taban Deng, Juba, South Sudan; DOB 01 Jan 1953; POB Kuerbona, South Sudan; nationality South Sudan; Gender Male (individual) [GLOMAG].

to their Global Magnitsky human rights & anti-corruption sanctions program.

Link:

OFAC Notice

Treasury Sanctions First Vice President of South Sudan Taban Deng Gai

PRESS STATEMENT

MICHAEL R. POMPEO, SECRETARY OF STATE

JANUARY 8, 2020

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State Department Press Release

Today, OFAC added the following people (apparently government officials, since E.O. 13876 is mentioned):

ABDOLLAHI, Ali (a.k.a. ABDOLLAHI ALIABADI, Ali), Iran; DOB 1959; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [IRAN-EO13876]. 

ASHTIANI, Mohammad-Reza (a.k.a. ASHTIANI, Mohammed Reza Gharayi), Iran; DOB 1960; alt. DOB 1961; POB Tehran, Iran; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [IRAN-EO13876]. 

QOMI, Mohsen, Iran; DOB 1960; POB Mamazand, Varamin, Tehran, Iran; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [IRAN-EO13876].

REZA’I, Mohsen (a.k.a. REZAEI, Mohsen; a.k.a. REZAI, Mohsen), Iran; DOB 1954; POB Masjed-e Soleyman, Iran; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [IRAN-EO13876]. 

SHAMKHANI, Ali, Iran; DOB 29 Sep 1955; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Admiral (individual) [IRAN-EO13876].

SOLEIMANI, Gholamreza (a.k.a. SOLEIMANI, Gholam Reza; a.k.a. SOLEYMANI, Gholam Reza), Iran; DOB 1964; alt. DOB 1965; POB Iran; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [IRAN-EO13876].

entities (under E.O. 13871, somehow connected to the metals industries):

ALMAHDI ALUMINUM CO. (a.k.a. AL MAHDI ALUMINUM COMPANY), 1st Floor, No. 12, Bibie Shahrbanoei Ally., West Saeb Tabrizi St., North Sheikh Bahaei St., Molla Sadra St., Vanak Sq., Tehran, Iran; 18th Km., Shahid Rajaee Quay Road, Bandar Abbas, Iran; Website http://almahdi.ir; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN-EO13871].

ARFA IRON AND STEEL COMPANY (a.k.a. ARFA IRON & STEEL COMPANY; a.k.a. ARFA STEEL), No. 4, 4th Floor, Iraj Allay, Nelson Mandela (Africa) Street, Tehran, Iran; 25 km into the Ardakan-Nain Road, Ardakan, Iran; Website http://www.arfasteel.com; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 242295 (Iran) [IRAN-EO13871].

CHADORMALU MINING & INDUSTRIAL COMPANY (a.k.a. CHADORMALU MINING & INDUSTRIAL CO.; a.k.a. CHADORMALU MINING & INDUSTRIAL PUBLIC JOINT STOCK COMPANY; a.k.a. CHADORMALU MINING AND INDUSTRIAL CO.; a.k.a. CHADORMALU MINING AND INDUSTRIAL COMPANY; a.k.a. CHADORMALU MINING AND INDUSTRIAL PUBLIC JOINT STOCK COMPANY), 56, Vali-e-Asr Street, Opposite the Prayer, Esfandyar Boulevard, Tehran 1968653647, Iran; Website http://www.chadormalu.com; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 145857 (Iran) [IRAN-EO13871].

ESFAHAN STEEL COMPANY (a.k.a. “ECSO”), End of Zob Ahan Highway- Esfahan Steel Company 8593111111, Iran; Townhid building, end of Zob Ahan Highway No. 178, Saadi Boulevard, The Steel Highway, Esfahan 81756-14461, Iran; PO Box 81756-14461, No. 178 Saadi Boulevard, Esfahan, Iran; Website http://www.esfahansteel.ir; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 25230 (Iran) [IRAN-EO13871].

GOLGOHAR MINING AND INDUSTRIAL COMPANY, No. 273, Dr. Fatemi Ave., Tehran 1414618551, Iran; 55 km, Shiraz Road, Sirjan, Kerman, Iran; PO Box 178185-111, Sirjan, Kerman, Iran; Website http://www.geg.ir; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN-EO13871].

HONGYUAN MARINE CO LTD (a.k.a. HONGYUAN MARINE CO LTD HONG UNION), Room 905, China Hong Centre, 717, Zhongxing Lu, Jiangdong Qu, Ningbo, Zhejiang 315040, China; R1003-1008, Heyuan Enterprise Square, 2993 Gonghexin Rd, Shanghai 315040, China; Website http://www.hong-union.com; Additional Sanctions Information – Subject to Secondary Sanctions; Identification Number IMO 5163651 [IRAN-EO13871].

HORMOZGAN STEEL COMPANY (a.k.a. “HOSCO”), Shahid Rejaei Port Road KM 13, Bandar Abbas, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN-EO13871].

IRAN ALLOY STEEL COMPANY (a.k.a. “IASCO”), No. 51 Mashahir Ave., Ghaem Magham Farhani St., Karimkhan St., Tehran, Iran; Azadegan Blvd., Martyr Dehghan Manshadi Blvd., Km 24, IASCO Road, Yazd, Iran; Website http://www.iasco.ir; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 2220 (Iran) [IRAN-EO13871].

IRAN ALUMINUM COMPANY (a.k.a. IRAN ALUMINIUM COMPANY; a.k.a. IRANIAN ALUMINUM COMPANY; a.k.a. IRAN’S ALUMINUM COMPANY; a.k.a. “IRALCO”), No. 49 Mullah Sadra Street, Vanaq Square, After Kurdistan Crossroads, Tehran, Iran; P.O. Box 3, Arak, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Registration ID 2600 (Iran) [IRAN-EO13871].

IRANIAN GHADIR IRON & STEEL CO. (a.k.a. IRANIAN GHADIR IRON AND STEEL CO.; a.k.a. “IGISCO”), 25th Km. Aradakan, Naein Road, Yazd, Iran; No. 1 34th Alley, Valiasr St., After Saei Park, Tehran, Iran; Website http://www.igisco.com; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN-EO13871].

KHALAGH TADBIR PARS CO., No. 18, Azadegan Alley, Qaem Maqam-e-Farahani St., Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN-EO13871].

KHORASAN STEEL COMPANY (a.k.a. KHORASAN STEEL COMPLEX JOINT STOCK COMPANY), PO Box 91735-866, 27, Felestine Boulevard, Mashhad, Iran; Website http://www.khorasansteel.com; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 6581 (Iran) [IRAN-EO13871].

KHOUZESTAN STEEL COMPANY (a.k.a. KHUZESTAN STEEL COMPANY), 10th Km. of Ahwaz-Bahdar Imam Khomeini Road, Ahwaz, Iran; PO Box 1378, Ahvaz, Khuzestan 61788-13111, Iran; Website http://www.ksc.ir; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 3199 (Iran) [IRAN-EO13871].

NATIONAL IRANIAN COPPER INDUSTRIES COMPANY (a.k.a. NATIONAL IRANIAN COPPER INDUSTRIES PUBLIC JOINT STOCK; a.k.a. “NICICO”), Next to Saei Park, Block No. 2161, Vali Asr Avenue, Tehran, Iran; PO Box 15115-416, Tehran, Iran; Website http://www.nicico.com; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 15957 (Iran) [IRAN-EO13871].

OXIN STEEL COMPANY (a.k.a. KHOUZESTAN OXIN STEEL COMPANY; a.k.a. KHOZESTAN OXIN STEEL COMPANY; a.k.a. KHUZESTAN OXIN STEEL COMPANY), Bandar Imam Khomeini (Blk) Road, 10 KM, Ahvaz 61788-13111, Iran; Website http://www.oxinsteel.ir; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 248247 (Iran) [IRAN-EO13871].

PAMCHEL TRADING BEIJING CO. LTD. (a.k.a. PAMCHEL ASIA CO., LTD; a.k.a. PAMCHEL ASIA STEEL GROUP COMPANY LIMITED), Room 328 Building 28, No. 17 Jianguomenwal Street Chaoyang District, Beijing, China; Rm. 503, Building No. 4, Xiandaicheng District, Beijing, China; Flat/Rm A, 9/F Silvercorp International Tower, 707-713 Nathan Road, Mongkok, Kowloon, Hong Kong; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN-EO13871] (Linked To: KHALAGH TADBIR PARS CO.).

POWER ANCHOR LIMITED, Mahe, Seychelles; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN-EO13871] (Linked To: PAMCHEL TRADING BEIJING CO. LTD.).

REPUTABLE TRADING SOURCE LLC (a.k.a. REPUTABLE TRADING SOURCE LLC COMPANY; a.k.a. “RTS LLC”), CR Number 1137785, PO Box: 888, Muscat 111, Oman; PO Box 1295: 111 CPO, Azaiba, Muscat, Oman; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 1137785 (Oman) [IRAN-EO13871] (Linked To: KHOUZESTAN STEEL COMPANY).

SABA STEEL (a.k.a. SABA STEEL COMPANY), KM 45 on Esfahan Shahrekord Road, Isfahan, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 5028 (Iran) [IRAN-EO13871].

SOUTH KAVEH STEEL COMPANY (a.k.a. KISH SOUTH KAVEH STEEL COMPANY; a.k.a. SKS STEEL COMPANY; a.k.a. “SKS CO.”), No. 1/2 Seventh Ave., North Falamak-zarafshan intersections, Phase 4, Shahrak-E Gharb, Tehran, Iran; Persian Gulf Special Economic Zone, 13th Km Shahid Rajaee Highway, Bandar Abbas, Hormozgan, Iran; Next to Behjat Park, No. 12, Apartment Complex Kaveh Golabi Stre, Karimkhan Zand Avenue, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 7103 (Iran) [IRAN-EO13871].

and a cargo vessel:

HONG XUN (D5GG9) Liberia flag; Additional Sanctions Information – Subject to Secondary Sanctions; Vessel Registration Identification IMO 9588885; MMSI 636016459 (vessel) [IRAN-EO13871] (Linked To: HONGYUAN MARINE CO LTD). 

under its Iran sanctions program.

Additionally, the following existing designations were updated:

And Treasury issued a press release:

Links:

OFAC Notice

Treasury Press Release

As was previously stated earlier in the week, on Friday, President Trump issued another Iran Executive Order (“Imposing Sanctions with Respect to Additional Sectors of Iran”). Here’s the operative part, which makes the new designations subject to primary and secondary sanctions:

Section 1.(a) All property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any United States person of the following persons are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in: any person determined by the Secretary of the Treasury, in consultation with the Secretary of State:

(i) to operate in the construction, mining, manufacturing, or textiles sectors of the Iranian economy, or any other sector of the Iranian economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State;

(ii) to have knowingly engaged, on or after the date of this order, in a significant transaction for the sale, supply, or transfer to or from Iran of significant goods or services used in connection with a sector of the Iranian economy specified in, or determined by the Secretary of the Treasury, in consultation with the Secretary of State, pursuant to, subsection (a)(i) of this section;

(iii) to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person whose property and interests in property are blocked pursuant to this order; or

(iv) to be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to this order.

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

Sec. 2. (a) The Secretary of the Treasury, in consultation with the Secretary of State, is hereby authorized to impose on a foreign financial institution the sanctions described in subsection (b) of this section upon determining that the foreign financial institution has, on or after the date of this order, knowingly conducted or facilitated any significant financial transaction:

(i) for the sale, supply, or transfer to or from Iran of significant goods or services used in connection with a sector of the Iranian economy specified in, or determined by the Secretary of the Treasury, in consultation with the Secretary of State, pursuant to, section 1(a)(i) of this order; or

(ii) for or on behalf of any person whose property and interests in property are blocked pursuant to section 1 of this order.

(b) With respect to any foreign financial institution determined by the Secretary of the Treasury, in consultation with the Secretary of State, in accordance with this section to meet the criteria set forth in subsection (a) of this section, the Secretary of the Treasury may prohibit the opening, and prohibit or impose strict conditions on the maintaining, in the United States of a correspondent account or a payable-through account by such foreign financial institution.

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

Links:

OFAC Notice

Executive Order

Earlier today, the Office of Foreign Assets Control (OFAC) added the following persons:

to their Venezuela sanctions program, and update the following Iran sanctions designation:

PAMCHEL TRADING BEIJING CO. LTD. (a.k.a. PAMCHEL ASIA CO., LTD; a.k.a. PAMCHEL ASIA STEEL GROUP COMPANY LIMITED), Room 328 Building 28, No. 17 Jianguomenwal Street Chaoyang District, Beijing, China; Rm. 503, Building No. 4, Xiandaicheng District, Beijing, China; Flat/Rm A, 9/F Silvercorp International Tower, 707-713 Nathan Road, Mongkok, Kowloon, Hong Kong; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN-EO13871] (Linked To: KHALAGH TADBIR PARS CO.). -to- PAMCHEL TRADING BEIJING CO. LTD. (a.k.a. PAMCHEL ASIA CO., LTD; a.k.a. PAMCHEL ASIA STEEL GROUP COMPANY LIMITED), Room 328 Building 28, No. 17 Jianguomenwal Street Chaoyang District, Beijing, China; Rm. 503, Building No. 4, Xiandaicheng District, Beijing, China; Flat/Rm A, 9/F Silvercorp International Tower, 707-713 Nathan Road, Mongkok, Kowloon, Hong Kong; Additional Sanctions Information – Subject to Secondary Sanctions [IFCA] [IRAN-EO13871](Linked To: KHALAGH TADBIR PARS CO.).  

Link:

OFAC Notice

The United States Takes Action against Officials of the Former Maduro Regime Involved in Obstructing the Venezuelan National Assembly

PRESS STATEMENT

MICHAEL R. POMPEO, SECRETARY OF STATE

JANUARY 13, 2020

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Of course, Mr. Watchlist wants to know whether any of these people have overseas assets. Dollars to donuts, they don’t.

Link:

State Department Press Release

Earlier this morning, OFAC added the following entities:

to its North Korean sanctions program.

Link:

OFAC Notice

Today, OFAC issued the following new Frequently Asked Question for its Iran sanctions program:

Links:

OFAC Notice

New FAQ

According to the Recent Actions page, OFAC has updated Venezuela General License 5B (Authorizing Certain Transactions Related to the Petroleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After April 22, 2020) and 8E (Authorizing Transactions Involving Petroleos de Venezuela, S.A. (PdVSA) Necessary for Maintenance of Operations for Certain Entities in Venezuela). At the time I first wrote this, the OFAC website was largely inoperative. It is now back up.

The change to General License 5B from 5A is that the authorized transactions, which were supposed to be as of January 22, 2020 are now as of April 22nd. Similarly, General License 8E now expires April 22nd.

Links:

OFAC Notice

General License 5B

General License 8E