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March 20, 2019: OFAC issues technical notice for its data files

March 22, 2019, 8:35 am
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Important technical notice for users of OFAC’s Sanctions List Data Files

3/20/2019

In early February of 2019, multiple users of OFAC’s data files contacted OFAC’s technical support hotline to report difficulty in downloading sanctions list data files hosted at this URL: https://www.treasury.gov/ofac/downloads/.  After investigating the issue, the Treasury Department discovered that changes had been made regarding HTTP request methods.  These changes generally affected users that leverage command line connections to Treasury’s website.  Users who download OFAC’s sanctions list data files manually via browser will not be impacted by this change.  

Previously users were allowed to request sanctions list data files via HTTP using both POST and GET commands.  The change made in February eliminated users’ ability to use the POST command and only GET commands are allowed henceforth.  This change was made to improve the security for public file repositories and is a permanent change.  Users who continue to have difficulty downloading OFAC’s sanctions list data files due to this change are welcome to contact OFAC at O_F_A_C@treasury.gov or contact OFAC’s technical support hotline at 1-800-540-6322 – Menu Option 8 for assistance.  

OFAC understands that this change may have unexpectedly interrupted users’ ability to download and access OFAC data and is working with Treasury’s technical team to ensure advance notification of any future changes. 

Link:

Technical notice

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March 22, 2019 OFAC Iran designations: Additional detail from the US Treasury

March 25, 2019, 6:00 am
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U.S. Government Sanctions Organizations and Individuals in Connection with an Iranian Defense Entity Linked to Iran’s Previous Nuclear Weapons Effort

WASHINGTON – The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), together with the U.S. Department of State, designated 14 individuals and 17 entities today in connection with Iran’s Organization of Defensive Innovation and Research (SPND), which has provided support to designated Iranian defense entities and whose key personnel played a central role in the Iranian regime’s past nuclear weapons effort.  This action targets current SPND subordinate groups, supporters, front companies, and associated officials.

“The U.S. government is taking decisive action against actors at all levels in connection with Iran’s Organization of Defensive Innovation and Research (SPND) who have supported the Iranian regime’s defense sector,” said Treasury Secretary Steven T. Mnuchin.  “The United States will continue applying maximum pressure to the Iranian regime, using all economic tools to prevent Iran from developing weapons of mass destruction. Anyone considering dealing with the Iranian defense industry in general, and SPND in particular, risks professional, personal, and financial isolation.”

The Department of State sanctioned SPND on August 29, 2014 pursuant to Executive Order (E.O.) 13382 for engaging in or attempting to engage in activities that have materially contributed to, or posed a risk of materially contributing to, the proliferation of WMD or their means of delivery.  E.O. 13382 provides authority to impose sanctions on proliferators of weapons of mass destruction (WMD) and their means of delivery and supporters.  Under its “Amad Plan,” Iran procured materials and equipment, and conducted a variety of activities, relevant to the development of a nuclear explosive device.  Iran also re-engineered a ballistic missile’s reentry vehicle for probable use as a delivery system for a nuclear weapon.  Scientists have engaged in proliferation-sensitive research and experiments on behalf of SPND organizations, which spend millions of dollars each year on a broad spectrum of defense-related projects. 

Shahid Karimi Group

OFAC designated Shahid Karimi Group, an SPND subordinate group that works on missile and explosives-related projects for SPND, and four associated individuals.  Shahid Karimi Group has conducted weapons systems, materials, and explosion research on behalf of SPND.  OFAC designated Shahid Karimi Group pursuant to E.O. 13382 for being owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, SPND.

Mohammad Reza Mehdipur is head of Shahid Karimi Group, and has been involved in explosion and shock research conducted on behalf of SPND.

Akbar Motallebizadeh previously was head of Shahid Karimi Group, where he supervised SPND projects.  Akbar Motallebizadeh also has served as an advisor to Mohsen Fakhrizadeh (Fakhrizadeh), the head of SPND.  Fakhrizadeh was designated pursuant to E.O. 13382 on July 8, 2008.

Jalal Emami Gharah Hajjlu was a weapons systems researcher at Shahid Karimi Group.  Jalal Emami Gharah Hajjlu also served as a senior expert and quality control manager for the Amad Plan.

Sa’id Borji is an explosives and metals expert for SPND’s Shahid Karimi Group who has assisted SPND’s efforts to procure equipment used for containing explosions.

OFAC designated Mohammad Reza Mehdipur pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, Shahid Karimi Group.  OFAC also designated Akbar Motallebizadeh, Jalal Emami Gharah Hajjlu, and Sa’id Borji pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, Shahid Karimi Group.

Shahid Chamran Group

Shahid Chamran Group’s work has included studies on electron acceleration and mass transfer.  This SPND subordinate group also has conducted research for SPND related to electromagnetics, pulse power, and wave generation.

Sayyed Asghar Hashemitabar has served as a managing expert at Shahid Chamran Group, where he has focused on pulse power research.

OFAC designated Shahid Chamran Group pursuant to E.O. 13382 for being owned or controlled by SPND.  OFAC designated Sayyed Asghar Hashemitabar pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, Shahid Chamran Group.

Shahid Fakhar Moghaddam Group

OFAC designated SPND subordinate group Shahid Fakhar Moghaddam Group (Shahid Fakhar) and two associated individuals.  Shahid Fakhar has worked on projects to construct explosion simulators and built radiation and neutron monitoring and detection systems.  Additionally, the entity helped SPND establish an institute dedicated to physics-related calculations.

Ruhollah Ghaderi Barmi (Ghaderi) is a director at Shahid Fakhar, where he oversees manufacturing and production.  Ghaderi has been involved in Shahid Fakhar’s attempts to procure X-ray equipment from foreign suppliers.

Mohammad Javad Safari (Safari) is a calculations and measurement expert at Shahid Fakhar. 

OFAC designated Shahid Fakhar Moghaddam Group pursuant to E.O. 13382 for being owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, SPND.  OFAC designated Ruhollah Ghaderi Barmi pursuant to E.O. 13382 for acting for or on behalf of, directly or indirectly, Shahid Fakhar Moghaddam Group.  OFAC designated Mohammad Javad Safari pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, Shahid Fakhar Moghaddam Group.

Additional SPND Subordinate Groups Designated Today

OFAC designated an additional 10 entities whose research and activities benefit SPND.

Sheikh Baha’i Science and Technology Research Center works on radiation and applied physics for SPND. 

Shahid Avini Group has conducted studies on nuclear terrorism, distinguishing sources of natural and manmade incidents, and treaties and conventions governing the use and testing of various WMD.

Shahid Baba’i Group designs high-powered lasers, and also researches photonics and semiconductors under the auspices of SPND.

Shahid Movahhed Danesh Group has assisted SPND with laser and photonics research.

Abu Reihan Group has provided support for SPND projects related to satellites and plasma technology, and worked on SPND’s missile projects.

Shahid Kazemi Group conducts acoustics-related research for SPND.

Shahid Shokri Science and Technology Research Group is an SPND subsidiary that focuses on radiation exposure.

Heidar Karar Research Group works on cyber defense systems for SPND.  Its computer network exploitation operators have targeted U.S. individuals and companies.

Shahid Zeinoddin Group has worked on biological research and developing biotechnologies for SPND.  Shahid Zeinoddin Group has studied treating various poisonings, drug delivery methods, and biological defense systems on behalf of SPND as well.

Bu Ali Group’s undertakings have ranged from building bioreactors to conducting lab work on DNA sequencing for SPND.

Sadra Research Center specializes in cognitive sciences and has studied ways to mentally improve Iran’s elite military personnel.

OFAC designated Shahid Avini Group pursuant to E.O. 13382 for being owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, SPND.  OFAC designated Sheikh Baha’i Science and Technology Research Center, Shahid Baba’i Group, Shahid Kazemi Group, Shahid Shokri Science and Technology Research Group, Heidar Karar Research Group, Bu Ali Group, and Sadra Research Center pursuant to E.O. 13382 for being owned or controlled by SPND.

OFAC designated Shahid Movahhed Danesh Group, Abu Reihan Group, and Shahid Zeinoddin Group pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or good or services in support of, SPND.

Additional Individuals Designated Today

OFAC also designated Gholam Reza Eta’ati (Eta’ati) and Mansur Asgari pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, SPND.

Eta’ati, who is an expert in applied physics, is an SPND senior manager who oversees some of SPND’s most sensitive projects.

Mansur Asgari has served as head of SPND’s Research and Technology Department.  Mansur Asgari previously was a manager under the Amad Plan, overseeing projects focused on explosives and exploding bridge-wire (EBW) detonators.

The U.S. Department of State designated Reza Ebrahimi (Ebrahimi) pursuant to E.O. 13382 for having engaged, or attempted to engage, in activities or transactions that have materially contributed to, or pose a risk of materially contributing to, the proliferation of WMD or their means of delivery (including missiles capable of delivering such weapons), including any efforts to manufacture, acquire, possess, develop, transport, transfer or use such items, for Iran, a foreign country of proliferation concern.

Ebrahimi served as head of Iran’s Aerospace Research Institute (ARI), leading the development of the Kavoshgar, a space launch vehicle based on the Shahab-3 ballistic missile.  Ebrahimi also worked on Iran’s Amad Plan, where he was involved in numerous explosive experiments relevant to the development of a nuclear weapon.

SPND Front and Cover Companies

OFAC also designated today three key SPND front and cover companies, and four of their senior officials.

Pulse Niru has provided, or attempted to provide, financial, material, technological or other support for, or good or services in support of, SPND.  Pulse Niru is a Tehran-based company that designs and manufactures pulse power devices, develops technology for controlled fusion, and produces particle accelerators.

Pulse Niru also has sought to procure equipment for SPND.  Pulse Niru procures some equipment and advanced technologies from Chinese, Russian, and other foreign suppliers.

Mohammad Mahdi Da’emi Attaran (Attaran) is a manager and senior executive at Pulse Niru.  A pulsed power expert, Attaran has spent over a decade working for Pulse Niru.  He was directly involved in Pulse Niru’s efforts to supply and provide specialized services to SPND.

Attaran also has lent his expertise to Iran’s Center for Innovation and Technology Cooperation (CITC).  CITC was designated pursuant to E.O. 13382 on July 12, 2012.  CITC is positioned to support a range of Iran’s WMD and military procurement objectives, and is assessed to facilitate procurement and technology transfers from the science community to the military.

Mohsen Shafa’i is Pulse Niru’s managing director and has worked on the design, testing, and production of new technologies at Pulse Niru.

OFAC designated Mohammad Mahdi Da’emi Attaran and Mohsen Shafa’i pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, Pulse Niru.

Iranian company Kimiya Pakhsh Shargh (KPS) is owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, SPND.  KPS is subordinate to SPND and takes directions from senior SPND officials.

KPS procures materials from foreign suppliers, such as radioisotopes.  While such radioisotopes have legitimate medical applications, they also can be used in processes that test and grade welds on pressurized piping and vessels, machined parts, high-capacity storage containers, and concrete.  The same materials also can be employed to identify structural irregularities caused by mechanical damage and corrosion, and to detect defects in metal castings.

Mehdi Masoumian (Masoumian), who is an SPND employee, serves as the managing director of KPS. 

Mohammad Hossein Haghighian’s (Haghighian’s) responsibilities as KPS’s commercial manager include handling customs and regulatory processes for importing goods.  Haghighian also oversees technical inspections of behalf of KPS.

OFAC designated Masoumian and Haghighian pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, SPND.

Paradise Medical Pioneers Company (PMP) is owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, SPND.  PMP is a cover company that researches and produces composites, steels, polymers, and other materials for customers including SPND.  PMP is administratively subordinate to SPND, and senior SPND officials, including SPND head Fakhrizadeh, hold various positions within the company.

Sanctions Implications

As a result of today’s action, all property and interests in property of these targets that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.  OFAC’s regulations generally prohibit all dealings by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated persons.

In addition, persons that engage in certain transactions with the individuals and entities designated today may themselves be exposed to sanctions or subject to an enforcement action.  Furthermore, unless an exception applies, any foreign financial institution that knowingly facilitates a significant transactions for any of the individuals or entities designated today could be subject to U.S. sanctions.

Lastly, today’s action serves as a warning to individuals and entities considering dealing with the Iranian regime’s defense sector in general, and SPND in particular: by engaging in sanctionable activity with designated Iranian persons, you risk professional, personal, and financial isolation.

Link:

Treasury Press Release

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March 22, 2019: OFAC designates BANDES and issues a slew of new Venezuela General Licenses

March 25, 2019, 6:25 am
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Friday afternoon, OFAC (without sending out email notifications like it usually does), designated the following entities: under its Venezuela sanctions program.

In addition, it modified General License 4, and added 4 new ones – 15 through 18:

In addition, OFAC is amending General License 4 – “Authorizing New Debt Transactions and Transactions involving Certain Banks Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, or Replacement Parts and Components,” and issuing the following four new Venezuela-related general licenses in connection with this designation:  General License 15 – “Authorizing Transactions Involving Certain Banks Prohibited by Executive Order 13850 for Certain Entities,” General License 16 – “Authorizing Maintenance of U.S. Person Accounts and Noncommercial, Personal Remittances involving Certain Banks,” General License 17 – “Authorizing Certain Activities Necessary to Wind Down of Operations or Existing Contracts with Certain Banks,” and General License 18 – “Authorizing Certain Transactions Involving Integracion Administradora de Fondos de Ahorro Previsional, S.A.” 

General License 4A explicitly says

This general license does not authorize:

(A) Any transactions or dealings with Banco de Desarrollo Economico y Social de Venezuela (BANDES) or Banco Bandes Uruguay S.A. (Bandes Uruguay);

I will post the full text of the other licenses separately.

And there were 2 new Frequently Asked Questions (FAQs), too:

Executive Order 13857 of January 25, 2019 “Taking Additional Steps to Address the National Emergency with Respect to Venezuela”. Please note that the FAQs in this section will be updated as appropriate to reflect the designation of PdVSA.  

649. What does Executive Order 13857 of January 25, 2019 “Taking Additional Steps to Address the National Emergency with Respect to Venezuela” do and how does this impact OFAC’s Venezuela-related sanctions?  

Executive Order 13857 of January 25, 2019 “Taking Additional Steps to Address the National Emergency with Respect to Venezuela” broadens the definition of the term “Government of Venezuela” to include persons that have acted, or have purported to act, on behalf of the Government of Venezuela, including members of the Maduro regime, for purposes of Executive Orders 13692, 13808, 13827, 13835, and 13850.  All existing Venezuela-related sanctions remain in effect. [01-28-2019] 

663. Does the Secretary of the Treasury’s determination on March 22, 2019, that persons operating in the financial sector of the Venezuelan economy may be subject to sanctions pursuant to Executive Order 13850, as amended, mean that all Venezuelan financial institutions have been sanctioned by OFAC as of March 22, 2019, and are now blocked persons?

No.  Only those persons listed on OFAC’s SDN List, and entities that they own, directly or indirectly, 50 percent or more of, are blocked persons and subject to sanctions pursuant to E.O. 13580, as amended. [03-22-2019] 

664. Can U.S. financial institutions process transactions and maintain correspondent accounts in connection with activities authorized under Venezuela General Licenses 4A, 15, 16, 17, and 18?

U.S. financial institutions and U.S. registered money transmitters are authorized to process transactions involving Banco de Venezuela, S.A. Banco Universal (Banco de Venezuela) or Banco Bicentenario del Pueblo, de la Clase Obrera, Mujer y Comunas, Banco Universal C.A. (Banco Bicentenario del Pueblo) for purposes of Venezuela General Licenses 4A, 15, 16, and 17, Banco Prodem S.A. for purposes of General License 17, and Integracion Administradora de Fondos de Ahorro Previsional, S.A. for purposes of General License 18, in each case so long as the underlying transaction or activity is authorized under the relevant general license.  

U.S. financial institutions that maintain correspondent accounts for Banco de Venezuela or Banco Bicentenario del Pueblo for purposes of General Licenses 4A, 15, 16, and 17, Banco Prodem S.A. for purposes of General License 17, and Integracion Administradora de Fondos de Ahorro Previsional, S.A. for purposes of General License 18 may debit or credit such accounts for transactions consistent with the activity authorized in the relevant general license. [03-22-2019]

And Treasury issued the following press release:

PRESS RELEASES

Treasury Sanctions BANDES, Venezuela’s National Development Bank, and Subsidiaries, in Response to Illegal Arrest of Guaido Aide

Washington – Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Banco de Desarrollo Economico y Social de Venezuela, or BANDES, pursuant to E.O. 13850, as amended, for operating in the financial sector of the Venezuelan economy, as well as four additional financial institutions that BANDES owns or controls.  

“The willingness of Maduro’s inner-circle to exploit Venezuela’s institutions knows no bounds.  Regime insiders have transformed BANDES and its subsidiaries into vehicles to move funds abroad in an attempt to prop up Maduro.  Maduro and his enablers have distorted the original purpose of the bank, which was founded to help the economic and social well-being of the Venezuelan people, as part of a desperate attempt to hold onto power,” said Treasury Secretary Steven T. Mnuchin.  “The regime’s continued use of kidnapping, torture, and murder of Venezuelan citizens will not be tolerated by the U.S. or the international coalition that is united behind President Guaido.  Roberto Marrero and other political prisoners must be released immediately.”

Today’s action designating BANDES and its subsidiaries follows a determination by Secretary of the Treasury, Steven T. Mnuchin, in consultation with Secretary of State Michael Pompeo, that persons operating in Venezuela’s financial sector may be subject to sanctions. 

The following entities designated today have been determined to operate in the financial sector of the Venezuelan economy, or are owned or controlled by an entity that operates in the financial sector of the Venezuelan economy:

  • BANDES is based in Venezuela, and is a state-owned and controlled bank.  As Venezuela’s national development bank, BANDES was created in order to promote the economic development and sustained growth of Venezuela, to include providing services such as monetary intermediation, credit, and security and commodity contracts brokerage services, among other financial and trust activities.  Simon Alejandro Zerpa Delgado, who was designated by OFAC pursuant to E.O. 13692 on July 26, 2017, is the Chief Executive and President of the Board of the bank.  
  • Banco Bandes Uruguay S.A. is based in Uruguay.  In early 2019, Maduro tried to move over one billion dollars out of Venezuela via BANDES to its subsidiary in Uruguay, Banco Bandes Uruguay S.A. 
  • Banco Bicentenario del Pueblo, de la Clase Obrera, Mujer y Comunias, Banco Universal C.A. is based in Venezuela. 
  • Banco de Venezuela, S.A. Banco Universal is based in Venezuela. 
  • Banco Prodem S.A. is based in Bolivia.

For information about the methods that Venezuelan senior political figures, their associates, and front persons use to move and hide corrupt proceeds, including how they try to exploit the U.S. financial system and real estate market, please refer to Treasury’s Financial Crimes Enforcement Network (FinCEN) advisories FIN-2017-A006, “Advisory on Widespread Public Corruption in Venezuela,” and FIN-2017-A003, “Advisory to Financial Institutions and Real Estate Firms and Professionals.”

As a result of today’s action, all property and interests in property of these entities, and of any entities that are owned, directly or indirectly, 50 percent or more by this entity, that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.  OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked or designated persons.

Concurrent with today’s action, OFAC announced five General Licenses.

U.S. sanctions need not be permanent; sanctions are intended to bring about a positive change of behavior.  The United States has made clear that the removal of sanctions is available for persons designated under E.O. 13692 or E.O. 13850, both as amended, who take concrete and meaningful actions to restore democratic order, refuse to take part in human rights abuses, speak out against abuses committed by the Maduro regime, and combat corruption in Venezuela.

Links:

OFAC Notice

General Licenses: 4A, 15, 16, 17, 18

Treasury Press Release

New FAQs

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HKMA Alert: Hong Leong Bank Berhad Phishing email

March 25, 2019, 6:30 am
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Press Releases

Phishing email related to Hong Leong Bank Berhad

The Hong Kong Monetary Authority (HKMA) wishes to alert members of the public to a press release issued by Hong Leong Bank Berhad on phishing email, which has been reported to the HKMA.  Hyperlink to the press release is available on the HKMA website for ease of reference by members of the public.

Anyone who has provided his or her personal information to the email concerned or has conducted any financial transactions through the email should contact the bank concerned using the contact information provided in the press release, and report to the Police or contact the Cyber Security and Technology Crime Bureau of the Hong Kong Police Force at 2860 5012.

 

Hong Kong Monetary Authority
24 January 2019

Link:

HKMA Notice

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Venezuela General License 15

March 25, 2019, 6:35 am
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GENERAL LICENSE NO. 15

Authorizing Transactions Involving Certain Banks Prohibited by Executive Order 13850 for Certain Entities

(a) Except as provided in paragraph (b) of this general license, all transactions and activities prohibited by Executive Order (E.O.) 13850, as amended by E.O. 13857 of January 25, 2019 (“Taking Additional Steps to Address the National Emergency With Respect to Venezuela”), that are ordinarily incident and necessary to the activities of the following entities, and their subsidiaries, which involve Banco de Venezuela, S.A. Banco Universal (Banco de Venezuela) or Banco Bicentenario del Pueblo, de la Clase Obrera, Mujer y Comunas, Banco Universal C.A. (Banco Bicentenario del Pueblo) are authorized through 12:01 a.m. eastern daylight time, March 22, 2020:

• MasterCard Incorporated

• Visa Inc.

• American Express Company

• Western Union Company

• MoneyGram International

(b) This general license does not authorize:

(1) Any transactions or dealings with Banco de Desarrollo Econornico y Social de Venezuela (BANDES) or Banco Bandes Uruguay S.A. (Bandes Uruguay);

(2) The unblocking of any property blocked pursuant to E.O. 13850, as amended by E.O. 13857, or any part of 31 C.F.R. chapter V, except as authorized by paragraph (a); or

(3) Any transaction that is otherwise prohibited under E.O. 13850 of November 1, 2018, E.O. 13835 of May 21, 2018, E.O. 13827 of March 19, 2018, E.O. 13808 of August 24, 2017, E.O. 13692 of March 8, 2015, each as amended by E.O. 13857, or any part of 31 C.F.R. chapter V, or any transactions or dealings with any blocked person other than the blocked persons described in paragraph (a) of this general license.

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Venezuela General License 16

March 25, 2019, 6:40 am
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GENERAL LICENSE NO. 16

Authorizing Maintenance of U.S. Person Accounts and Noncommercial, Personal Remittances involving Certain Banks

(a) Except as provided in paragraph (d) of this general license, the following transactions and activities involving Banco de Venezuela, S.A. Banco Universal (Banco de Venezuela) or Banco Bicentenario del Pueblo, de la Clase Obrera, Mujer y Comunas, Banco Universal C.A. (Banco Bicentenario del Pueblo) prohibited by Executive Order (E.O.) 13850, as amended by E.O. 13857 of January 25, 2019 (“Taking Additional Steps to Address the National Emergency With Respect to Venezuela”), are authorized through 12:01 a.m. eastern daylight time, March 22, 2020:

(1) All transactions and activities ordinarily incident and necessary to maintaining, operating, or closing accounts of U.S. persons in Banco de Venezuela or Banco Bicentenario del Pueblo; and

(2) All transactions and activities ordinarily incident and necessary to processing noncommercial, personal remittances.

(b) Noncommercial, personal remittances do not include charitable donations of funds to or for the benefit of an entity or funds transfers for use in supporting or operating a business, including a family-owned business.

(c) U.S. financial institutions processing transactions authorized by paragraph (a)(2) of this general license may rely on the originator of a funds transfer with regard to compliance with paragraph (a)(2), provided that the transferring institution does not know or have reason to know that the funds transfer is not in compliance with paragraph (a)(2).

(d) This general license does not authorize:

(1) Any transactions or dealings with Banco de Desarrollo Economico y Social de

Venezuela (BANDES) or Banco Bandes Uruguay S.A. (Bandes Uruguay);

(2) The unblocking of any property blocked pursuant to E.O. 13850, as amended by E.O. 13857, or any part of 31 C.F.R. chapter V, except as authorized by paragraph (a); or

(3) Any transaction that is otherwise prohibited under E.O. 13850 of November 1, 2018, E.O. 13835 of May 21, 2018, E.O. 13827 of March 19, 2018, E.O. 13808 of August 24, 2017, E.O. 13692 of March 8, 2015, each as amended by E.O. 13857, or any part of 31 C.F.R. chapter V, or any transactions or dealings with any blocked person other than the blocked persons described in paragraph (a) of this general license.

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Venezuela General License 17

March 25, 2019, 6:45 am
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GENERAL LICENSE NO. 17

Authorizing Certain Activities Necessary to Wind Down of Operations or Existing Contracts with Certain Banks

(a) Except as provided in paragraph (b) of this general license, all transactions and activities prohibited by Executive Order (E.O.) 13850, as amended by E.O. 13857 of January 25, 2019 (“Taking Additional Steps to Address the National Emergency With Respect to Venezuela”), that are ordinarily incident and necessary to the wind down of operations, contracts, or other agreements involving Banco de Venezuela, S.A. Banco Universal (Banco de Venezuela), Banco Bicentenario del Pueblo, de la Clase Obrera, Mujer y Comunas, Banco Universal C.A. (Banco Bicentenario del Pueblo), or Banco Prodem S.A. that were in effect prior to March 22, 2019, are authorized through 12:01 a.m. eastern daylight time, May 21, 2019.

(b) This general license does not authorize:

(1) Any transactions or dealings with Banco de Desarrollo Economico y Social de Venezuela (BANDES) or Banco Bandes Uruguay S.A. (Bandes Uruguay);

(2) The unblocking of any property blocked pursuant to E.O. 13850, as amended by E.O. 13857, or any part of 31 C.F.R. chapter V, except as authorized by paragraph (a); or

(3) Any transactions or dealings otherwise prohibited by E.O. 13850 of November 1, 2018, E.O. 13835 of May 21, 2018, E.O. 13827 of March 19, 2018, E.O. 13808 of August 24, 2017, E.O. 13692 of March 8, 2015, each as amended by E.O. 13857, or any part of 31 C.F.R. chapter V, or any transactions or dealings with any blocked person other than the blocked persons identified in paragraph (a) of this general license.

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Venezuela General License 18

March 25, 2019, 6:50 am
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GENERAL LICENSE NO. 18

Authorizing Certain Transactions Involving Integraci6n Administradora de Fondos de Ahorro Previsional, S.A.

(a) Except as provided in paragraph (c) of this general license, all transactions and activities prohibited by Section l(b) of Executive Order (E.O.) 13808, as amended by E.O. 13857 of January 25, 2019 (“Taking Additional Steps to Address the National Emergency With Respect to Venezuela”), or E.O. 13850, as amended by E.O. 13857, that are ordinarily incident and necessary to maintain or operate lntegraci6n Administradora de Fondos de Ahorro Previsional, S.A., whose fund administrator is owned 50 percent or more by Banco Bandes Uruguay S.A. (Bandes Uruguay), are authorized.

(b) For the purposes of this general license, the transactions and activities authorized in paragraph (a) include the purchase from or sale to the Integraci6n Administradora de Fondos de Ahorro Previsional, S.A. of securities or serving as a custodian for securities held by the Integraci6n Administradora de Fondos de Ahorro Previsional, S.A.

(c) This general license does not authorize:

(1) Any transactions or dealings with Banco de Desarrollo Economico y Social de Venezuela (BANDES), or any transactions or dealings with Bandes Uruguay, other than as authorized by paragraph (a) of this general license;

(2) The unblocking of any property blocked pursuant to E.O. 13850, as amended by E.O. 13857, or any part of 31 C.F.R. chapter V, except as authorized by paragraph (a); or

(3) Any transaction that is otherwise prohibited under E.O. 13850 of November 1, 2018, E.O. 13835 of May 21, 2018, E.O. 13827 of March 19, 2018, E.O. 13808 of August 24, 2017, E.O. 13692 of March 8, 2015, each as amended by E.O. 13857, or any part of 31 C.F.R. chapter V, or any transactions or dealings with any blocked person other than the blocked persons described in paragraph (a) of this general license.

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State Department Statement on BANDES designation

March 25, 2019, 7:39 am
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The United States Sanctions Venezuela’s State-affiliated Bank

Press Statement

Robert Palladino 
Deputy Spokesperson

Washington, DC

March 22, 2019

Today, the United States sanctioned the Venezuelan Economic and Social Development Bank (BANDES) and five subsidiaries (Banco Bandes Uruguay S.A., Banco de Venezuela S.A., Banco Universal, Banco Bicentenario del Pueblo, and Banco Prodem S.A.). In addition, the U.S. government today determined that persons operating in Venezuela’s financial sector could be subject to sanctions pursuant to Executive Order 13850. This action targets a financial institution that the former Maduro regime uses to move money stolen from the Venezuelan people outside of Venezuela.

The former Maduro regime continues its attack on democracy in Venezuela. This action is in response to the unjustified raids of the homes of several Venezuelan leaders, including National Assembly Deputy Sergio Vergara, and the abduction of Roberto Marrero, Chief of Staff to interim President Juan Guaido and Vergara’s driver, Luis Aguilar.

The former Maduro regime dispatched thugs to plant evidence in the homes of these Venezuelan leaders in the middle of the night, and continues to use lawless bands as a means to intimidate, stifle democracy, and silence the voice of the Venezuelan people. These unconscionable acts will not stand. Neither will the regime’s continued mismanagement and theft of Venezuela’s resources.

We demand the release of Roberto Marrero and Luis Aguilar immediately, and will hold accountable all those involved.

We will continue to use the full weight of U.S. economic and diplomatic power to press for the freedom of the Venezuelan people and restoration of Venezuelan democracy.

The international community stands with interim President Guaido, the National Assembly, and the people of Venezuela.

Link:

State Department Press Release

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DFSA Alert: Impersonation scam

March 25, 2019, 7:40 am
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ALERTS

DFSA Impersonated in a Fraudulent Scam

21 Mar 2019

The Dubai Financial Service Authority (DFSA) alerts the financial services community and members of the public about a fraudulent scheme in which the DFSA has been impersonated.

The scammers use a fake document as part of the scam, to attempt to charge potential customers to set up a meeting with a legitimate DFSA Authorised Firm, which has no knowledge of the document and no connection to the scammers. The document uses the DFSA’s logo without authority and for a malicious purpose. The document is a false “Non-Circumvention, Non-Disclosure Agreement” and a copy can be found here.

The DFSA informs you that:
• it does not allow the use of its logo for Authorised Firms to enter into agreements; and
• it does not charge fees for meetings of any sort.

The DFSA strongly advises that individuals do not respond to any communication regarding the scam, and under no circumstances should they send any money to any party involved in the scam.
The DFSA has a page on its website dedicated to alerts which it has issued about scams. All alerts issued by the DFSA may be accessed by going to: ALERTS

The DFSA has also issued warnings and guidance about the common types of scams perpetrated on consumers. For more information on these scams, please go to: HOW TO AVOID BEING SCAMMED

The DFSA encourages consumers to refer to the list of regulated Firms and Authorised Individuals licensed by the DFSA that is available on the DFSA’s PUBLIC REGISTER

If you have any concerns about the authenticity of any correspondence or documents that purport to be issued by the Dubai International Financial Centre (DIFC), DFSA or a DFSA regulated Firm, you should direct your concerns to the DIFC on Tel:+971 4 362 2222 and to the DFSA via the DFSA Complaints function on: COMPLAINTS

Link:

DFSA Notice

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UN, OFSI add Tariq Gidar Group to counter terror sanctions

March 25, 2019, 7:43 am
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Today, under the authority of the United Nations and European Union Financial Sanctions (Linking) Regulations, UK regulators added the following entity to its ISIL (Da’esh) and Al-Qaida counter terrorism sanctions program:

TARIQ GIDAR GROUP (TGG)

a.k.a: (1) COMMANDER TARIQ AFRIDI GROUP (2) TARIQ AFRIDI

GROUP (3) TARIQ GEEDAR GROUP (4) TARIQ GIDAR AFRIDI GROUP (5) TEHREEK- I-TALIBAN PAKISTAN GEEDAR GROUP (6) TEHRIK-E-TALIBAN-TARIQ GIDAR

GROUP (7) THE ASIAN TIGERS (8) TTP GEEDAR GROUP (9) TTP-TARIQ GIDAR GROUP Address: Afghanistan/Pakistan border region. Other Information: UN Ref: QDe.160. Splinter group of Tehrik-e Taliban Pakistan (TTP) (QDe.132). The group was formed in Darra Adam Khel, Federally Administered Tribal Area (FATA), Pakistan, in 2007. (Listing to be treated as temporary for 30 days from the date of listing by the UN or until the EU adds the new listing to an existing sanctions regulation (whichever is sooner) in accordance with Policing and Crime Act 2017). Listed on: 25/03/2019 Last Updated: 25/03/2019 Group ID: 13786.

Link:

OFSI Notice

UN Press Release

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HK SFC AML/CTF Circular: FATF statements

March 26, 2019, 6:10 am
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Circular to Licensed Corporations and Associated Entities 

Anti-Money Laundering / Counter-Financing of Terrorism 

(1)  FATF Statement on Democratic People’s Republic of Korea and Iran

(2)  FATF Statement on Improving Global AML/CFT Compliance: On-Going Process

(3)  Outcomes from the Meeting of the FATF Plenary, 20-22 February 2019

(1)  FATF Statement on Democratic People’s Republic of Korea and Iran

Further to our circular issued on 29 October 2018, this is to inform you that the Financial Action Task Force (“FATF”) issued an updated statement on 22 February 2019 identifying jurisdictions that have strategic deficiencies in their anti-money laundering and combating the financing of terrorism (“AML/CFT”) regimes.

The statement Note 1 has been separated into two sections.

(i)   Jurisdiction subject to a call on its members and other jurisdictions to apply counter-measures

Democratic People’s Republic of Korea (“DPRK”)

The FATF remains concerned by the DPRK’s failure to address the significant deficiencies in its AML/CFT regime and the serious threat this poses to the integrity of the international financial system.  Further, the FATF has serious concerns with the threat posed by the DPRK’s illicit activities related to the proliferation of weapons of mass destruction (“WMDs”) and its financing.  The FATF calls on its members and other jurisdictions to continue to apply counter-measures and targeted financial sanctions in accordance with applicable United Nations Security Council (“UNSC”) Resolutions to protect the international financial system from the on-going and substantial money laundering, terrorist financing and WMD proliferation financing risks emanating from the jurisdiction.

Licensed corporations (“LCs”) and associated entities (“AEs”) should give special attention to business relationships and transactions with the DPRK, including DPRK companies, financial institutions and those acting on their behalf, and subject them to increased scrutiny and enhanced due diligence measures.

In addition, LCs and AEs are reminded that it is an offence under section 4 of the Weapons of Mass Destruction (Control of Provision of Services) Ordinance (Cap. 526) for a person to provide any services where he believes or suspects, on reasonable grounds, that those services may be connected to WMD proliferation.

(ii)    Jurisdiction subject to a call on its members and other jurisdictions to apply enhanced due diligence measures proportionate to the risks arising from the jurisdiction 

Iran

In June 2016, the FATF welcomed Iran’s adoption of an action plan to address its strategic AML/CFT deficiencies and suspended counter-measures accordingly. In November 2017, Iran established a cash declaration regime. In August 2018, Iran has enacted amendments to its Counter-Terrorist Financing Act and in January 2019, Iran has also enacted amendments to its Anti-Money Laundering Act. The bills (which are not yet in force) to ratify the Palermo and Terrorist Financing Conventions have passed the Parliament. However, Iran’s action plan has expired with a number of items remains outstanding.

The FATF decided in the recent Plenary Meeting to continue the suspension of counter-measures noting the progress of the legislative efforts of Iran. While welcoming the passage of the Anti-Money Laundering Act, the FATF expresses its disappointment that the action plan to address Iran’s strategic AML/CFT deficiencies remains outstanding and expects Iran to proceed swiftly in the reform path to ensure that it addresses all of the remaining items by completing and implementing the necessary AML/CFT reforms. If by June 2019, Iran does not enact the remaining legislation in line with FATF standards, then the FATF will require increased supervisory examination for branches and subsidiaries of financial institutions based in Iran.

Until Iran fully implements the measures required to address the deficiencies identified with respect to countering financing of terrorism in the action plan, the FATF remains concerned with the risk of terrorist financing emanating from Iran and the threat this poses to the international financial system.  The FATF calls on its members and other jurisdictions to continue to apply enhanced due diligence measures proportionate to the risks arising from the jurisdiction.

LCs and AEs should apply enhanced due diligence measures, including obtaining information on the reasons for intended transactions, and conducting enhanced monitoring of business relationships, by increasing the number and timing of controls applied, and selecting patterns of transactions that need further examination, to business relationships and transactions with natural and legal persons from Iran. LCs and AEs are further advised that the type of enhanced due diligence measures applied should be effective and proportionate to the risks, and in line with the standards as specified in the FATF statement Note 1.

(2)  FATF Statement on Improving Global AML/CFT Compliance: On-Going Process

In addition, please be informed that as part of the on-going process to improve global AML/CFT compliance, the FATF has set out in a separate statement an updated list of jurisdictions that have strategic AML/CFT deficiencies for which they have developed an action plan with the FATF.  The FATF will closely monitor the implementation of those action plans and encourage its members to consider the information presented in the statement which can be found on the website of the FATF (http://www.fatf-gafi.org/publications/high-riskandnon-cooperativejurisdictions/documents/fatf-compliance-february-2019.html).

As the FATF will continue to assess the progress made by these jurisdictions in addressing the deficiencies in their AML/CFT systems and issue updated statements from time to time, LCs and AEs are reminded to browse the website of the FATF for the latest information.

(3)  Outcomes from the Meeting of the FATF Plenary, 20-22 February 2019 

In addition to the statements in (1) and (2) above, the FATF has also published various other outcomes of its recent Plenary Meeting which may be of interest to LCs and AEs. They include, for example, (i) FATF’s current action to combat terrorist financing, and (ii) Interpretive Note to FATF Recommendation 15 for mitigating risks from virtual assets. Further information can be found on the website of FATF (http://www.fatf-gafi.org/publications/fatfgeneral/documents/outcomes-plenary-february-2019.html).

Should you have any queries regarding the contents of this circular, please contact Ms Kiki Wong at 2231 1569 who will assist to refer your queries to the relevant officer.

Intermediaries Supervision Department
Intermediaries Division
Securities and Futures Commission

End

SFO/IS/007/2019

Links:

HK SFC Notice

HK SFC Circular

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March 25, 2019: OFAC updates Syria Shipping Advisory

March 26, 2019, 6:15 am
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On Monday, OFAC issued an updated version of its November advisory to the maritime shipping industry that highlighted risks of shipments made to Syria. And the Treasury Department issued the following press release:

Updated Treasury Advisory Highlights Risks for Maritime Petroleum Shipping Community in Syria

Dozens of new vessels involved in illicit oil shipments added

WASHINGTON – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated its Advisory to the Maritime Petroleum Shipping Community to highlight risks associated with shipments to Syria.  This advisory updates Treasury’s November 20, 2018 Advisory to include additional guidelines and risks associated with facilitating the shipment of petroleum destined for Syrian Government-owned and –operated ports, to include petroleum of Iranian origin.  It adds dozens of new vessels involved in illicit oil shipments, including 16 shipping to Syria and more than 30 engaging in ship-to-ship transfers, and highlights concerns with shipments of petroleum from Iran.

“Treasury has previously exposed a far-reaching oil for terror network involving Iran and Syria, and continues to target ships and companies facilitating illicit trade.  The United States has made it clear to the maritime shipping community that we will not tolerate the use of petroleum as a mechanism to finance rogue regimes in Iran and Syria.  As Iran and Syria attempt to adapt their illicit tactics and shift to new vessels, we will continue to provide these updates to the shipping community,” said Under Secretary for Terrorism and Financial Intelligence, Sigal Mandelker.  “Shipping companies, insurers, vessel owners, managers, and operators must aggressively counter the ongoing deceptive shipping practices deployed by Iran and Syria and other questionable jurisdictions.  Any violations of prohibitions or weaknesses in compliance that result in sanctionable conduct exposes the shipping community to significant risks and can trigger severe consequences.”

The new iteration of the Advisory includes major updates to its annex, which lists vessels that have delivered petroleum to Syria since 2016.  The annex also includes vessels that have engaged in ship-to-ship (STS) transfers of petroleum likely destined for Syria, as well as vessels which have exported Syrian petroleum.  Many of the names of the vessels have also been updated to reflect name changes.

A link to the updated Advisory (as well as to the North Korea one updated last week) appears on the Guidance and Resources page.

Links:

OFAC Notice

Updated Syria Shipping Advisory

Treasury Press Release

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UN, OSFI, DFAT add Tariq Gidar Group to counter terror sanctions

March 26, 2019, 7:50 am
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Today, Canadian and Australian regulators added the following entity:

QDe.160 Name: TARIQ GIDAR GROUP (TGG)
Name (original script): طارق گیدڑ گروپ
A.k.a.: a) TEHRIK-E-TALIBAN-TARIQ GIDAR GROUP b) TTP-TARIQ GIDAR GROUP c) TEHREEK-I-TALIBAN PAKISTAN GEEDAR GROUP d) TTP GEEDAR GROUP e) TARIQ GEEDAR GROUP f) COMMANDER TARIQ AFRIDI GROUPg) TARIQ AFRIDI GROUP h) TARIQ GIDAR AFRIDI GROUP i) THE ASIAN TIGERS F.k.a.: na Address: (Afghanistan/Pakistan border region) Listed on: 22 Mar. 2019 Other information: Splinter group of Tehrik-e Taliban Pakistan (TTP) (QDe.132). The group was formed in Darra Adam Khel, Federally Administered Tribal Area (FATA), Pakistan, in 2007.  INTERPOL-UN Security Council Special Notice web link:  www.interpol.int/en/notice/search/une/xxxx.

to their counter terrorism sanctions, after its addition by the United Nations ISIL (Da’esh) and Al-Qaida Sanctions Committee.

Links:

OSFI Notice

UN Notices – PDF (DFAT), HTML (OSFI)

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Another major round of OFAC Iran designations

March 26, 2019, 7:57 am
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Today, OFAC added the following people:

ALE ALI, Mohammad Reza; POB Shemiran, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 0451519639 (Iran) (individual) [SDGT] [IFSR] (Linked To: ANSAR EXCHANGE). 

 

ATABAKI, Alireza; DOB 1961; POB Tehran Province, Central Tehran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 0042773296 (Iran) (individual) [SDGT] [IRGC] [IFSR] (Linked To: ANSAR EXCHANGE). 

 

DASTGIRI, Reza Sakan; POB West Azerbaijan, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 2830283775 (Iran) (individual) [SDGT] [IFSR] (Linked To: SAKAN GENERAL TRADING). 

 

EBRAHIMI, Ayatollah; DOB 1972; POB Qomshaneh, Hamadan Province, Iran; Additional Sanctions Information – Subject to Secondary Sanctions (individual) [SDGT] [IRGC] [IFSR] (Linked To: ANSAR BANK). 

 

GALESHKALAMI, Iman Sedaghat; POB Gilan, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 2709803755 (Iran) (individual) [SDGT] [IFSR] (Linked To: ZAGROS PARDIS KISH; Linked To: MINISTRY OF DEFENSE AND ARMED FORCES LOGISTICS). 

 

MULAVI, Ali Shams (a.k.a. MOULAVI, Ali Shams), Turkey; DOB 23 Jul 1980; Additional Sanctions Information – Subject to Secondary Sanctions; Passport I95726252 (Iran) (individual) [SDGT] [IFSR] (Linked To: ANSAR EXCHANGE). 

 

SAKAN, Suleyman, Turkey; DOB 25 Sep 1965; Additional Sanctions Information – Subject to Secondary Sanctions; Passport U06595028 (Turkey) (individual) [SDGT] [IFSR] (Linked To: ANSAR EXCHANGE). 

 

SEIFI, Asadollah (a.k.a. SEIFY, Asadollah; a.k.a. SEYFI, Esdaleh); DOB 04 Apr 1965; Additional Sanctions Information – Subject to Secondary Sanctions (individual) [SDGT] [IFSR] (Linked To: ATLAS EXCHANGE). 

 

VAKILI, Mohammad, United Arab Emirates; DOB 22 Jun 1974; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 0082676984 (Iran); Birth Certificate Number 9444 (Iran) (individual) [SDGT] [IFSR] (Linked To: ATABAKI, Alireza).

and entities:

ANSAR BANK BROKERAGE COMPANY (f.k.a. PAR GOSTAR KHOBREH), Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Business Registration Number 24467 (Iran) [SDGT] [IRGC] [IFSR] (Linked To: ANSAR BANK). 

 

ANSAR EXCHANGE (a.k.a. SARAFI ANSAR; a.k.a. SARAFI ANSAR COMPANY), No. 41, Joibar Street, Fatemi Square, Tehran, Iran; Website Ansarexchange.ir; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 10320743975 (Iran); Business Registration Number 423264 (Iran) [SDGT] [IRGC] [IFSR] (Linked To: ANSAR BANK; Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE; Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 

 

ANSAR INFORMATION TECHNOLOGY COMPANY (f.k.a. FANAVARAN HAFIZEH SAMANEH), No. 59, West Taban Street, Jordon (Nelson Mandela) Street, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Business Registration Number 190617 (Iran) [SDGT] [IRGC] [IFSR] (Linked To: ANSAR BANK). 

 

ATLAS DOVIZ TICARETI A.S. (a.k.a. ATLAS DOVIZ), Tayahatun Mah., Tclar Sok. No: 83, Mercan Kaps-Kapal Car, Eminonu, Istanbul, Turkey; Website http://www.atlasdoviz.com; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: SAKAN, Suleyman). 

 

ATLAS EXCHANGE (a.k.a. ATLAS CURRENCY EXCHANGE; a.k.a. TAZAMONI VAKILI AND PARTNERS; a.k.a. VAKILI JOINT PARTNERSHIP), No. 77, Commercial Center Market (Bazar Markazi Tejari), Ferdosi Street, Kish Island, Iran; Website http://www.atlassarafi.com; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: ANSAR EXCHANGE). 

 

GOLDEN COMMODITIES LLC, 1805, Al Owais Tower, Baniyas Road, Deira, Dubai, United Arab Emirates; P.O. Box 31662, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: SEIFI, Asadollah). 

 

HITAL EXCHANGE (a.k.a. SARAFI SEYYED MOHAMMAD REZA ALE ALI AND PARTNERS; a.k.a. SEYYED MOHAMMAD REZA ALE ALI CURRENCY EXCHANGE), No. 2486, Tolu Shopping Center, Vali Asr Street, Tavanir Street, Tehran 1434853851, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 14005467510 (Iran); Registration Number 483939 (Iran) [SDGT] [IFSR] (Linked To: ALE ALI, Mohammad Reza). 

 

IRANIAN ATLAS COMPANY, No. 5, 10th Baharestan, Pasdaran Street, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Business Registration Number 59784 (Iran) [SDGT] [IRGC] [IFSR] (Linked To: ANSAR BANK). 

 

LEBRA MOON GENERAL TRADING LLC, Office 503, Centurion Star Building B, Al Etihad Road, Port Saeed, Dubai, United Arab Emirates; P.O. 185331, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions; License 735469 (United Arab Emirates) [SDGT] [IFSR] (Linked To: MINISTRY OF DEFENSE AND ARMED FORCES LOGISTICS; Linked To: ANSAR EXCHANGE). 

 

NARIA GENERAL TRADING LLC, Office 503, Centurion Star Building B, Al Etihad Road, Port Saeed, Dubai, United Arab Emirates; P.O. Box 185331, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions; License 751444 (United Arab Emirates) [SDGT] [IFSR] (Linked To: ANSAR EXCHANGE). 

 

SAKAN EXCHANGE (a.k.a. JOINT PARTNERSHIP OF REZA SAKAN DASTGIRI AND ASSOCIATES; a.k.a. TAZAMONI REZA SAKAN DASTGIRI VA SHORAK), No. 22, First Floor, Islaelzadeh Building, Shahid Javad Ghanbari Street, Bazargan, Maku Free Trade Zone, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 14003282053 (Iran) [SDGT] [IFSR] (Linked To: DASTGIRI, Reza Sakan). 

 

SAKAN GENERAL TRADING (a.k.a. ROYAL CREDIT GENERAL TRADING; a.k.a. SAKAN GENERAL TRADING, LLC), 14th Floor, Office 1401, Al Owais Business Tower, 53, 24th Street, Al Sabkha-115, Deira, Dubai, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions; License 611462 (United Arab Emirates) [SDGT] [IFSR] (Linked To: ANSAR EXCHANGE). 

 

THE BEST LEADER GENERAL TRADING LLC (a.k.a. WILMINGTON GENERAL TRADING LLC), 1805, Al Owais Tower, Binias Road, Deira, Dubai, United Arab Emirates; P.O. 31622, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions; License 668722 (United Arab Emirates) [SDGT] [IFSR] (Linked To: SEIFI, Asadollah). 

 

ZAGROS PARDIS KISH, No. 192, Pardis 1 Market, Kish Island 794188338, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 10980205334 (Iran); Business Registration Number 8953 (Iran) [SDGT] [IRGC] [IFSR] (Linked To: MINISTRY OF DEFENSE AND ARMED FORCES LOGISTICS; Linked To: ATABAKI, Alireza). 

 

to its Iran and counter terrorism sanctions programs.

Additionally, the following 2 listings were updated:

ANSAR BANK (a.k.a. ANSAR FINANCE AND CREDIT FUND; a.k.a. ANSAR FINANCIAL AND CREDIT INSTITUTE; a.k.a. BANK-E ANSAR; f.k.a. “ANSAR AL-MOJAHEDIN NO-INTEREST LOAN INSTITUTE”; f.k.a. “ANSAR INSTITUTE”; f.k.a. “ANSAR SAVING AND INTEREST FREE-LOANS FUND”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran; North Pasdaran St., No. 539, Before Sahebgharanieh, corner of Narenjestan dahom, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN] [NPWMD] [IFSR]. -to- ANSAR BANK (a.k.a. ANSAR FINANCE AND CREDIT FUND; a.k.a. ANSAR FINANCIAL AND CREDIT INSTITUTE; a.k.a. BANK ANSAR; a.k.a. BANK-E ANSAR; f.k.a. “ANSAR AL-MOJAHEDIN NO-INTEREST LOAN INSTITUTE”; f.k.a. “ANSAR INSTITUTE”; f.k.a. “ANSAR SAVING AND INTEREST FREE-LOANS FUND”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran; Website http://www.ansarbank.com; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN] [SDGT] [NPWMD] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE; Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 

 

MINISTRY OF DEFENSE FOR ARMED FORCES LOGISTICS (a.k.a. MINISTRY OF DEFENSE AND SUPPORT FOR ARMED FORCES LOGISTICS; a.k.a. MODAFL; a.k.a. MODSAF), located on the west side of Dabestan Street, Abbas Abad District, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR]. -to- MINISTRY OF DEFENSE AND ARMED FORCES LOGISTICS (a.k.a. GOVERNMENT OF IRAN DEPARTMENT OF DEFENSE; a.k.a. MINISTRY OF DEFENCE & ARMED FORCES LOGISTICS; a.k.a. MINISTRY OF DEFENSE AND SUPPORT FOR ARMED FORCES LOGISTICS; a.k.a. MINISTRY OF DEFENSE ARMED FORCES LOGISTICS; a.k.a. MINISTRY OF DEFENSE FOR ARMED FORCES LOGISTICS; a.k.a. MODAFL; a.k.a. MODSAF; a.k.a. VEZARATE DEFA; a.k.a. VEZARAT-E DEFA VA POSHTYBANI-E NIRU-HAYE MOSALLAH), Ferdowsi Avenue, Sarhang Sakhaei Street, Tehran, Iran; PO Box 11365-8439, Pasdaran Ave., Tehran, Iran; West side of Dabestan Street, Abbas Abad District, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [NPWMD] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE).  

And Treasury issued the following press release:

United States Disrupts Large Scale Front Company Network Transferring Hundreds of Millions of Dollars and Euros to the IRGC and Iran’s Ministry of Defense

WASHINGTON – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action against 25 individuals and entities, including a network of Iran, UAE, and Turkey-based front companies, that have transferred over a billion dollars and euros to the Islamic Revolutionary Guard Corps (IRGC) and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL), in addition to procuring millions of dollars’ worth of vehicles for MODAFL.  Today’s action exposes an extensive sanctions evasion network established by the Iranian regime, which it increasingly relies on as the United States’ maximum pressure campaign severely constricts the regime’s sources of revenue.  OFAC also designated Iran’s MODAFL pursuant to Executive Order (E.O.) 13224 for its role in assisting the IRGC-Qods Force (IRGC-QF), as well as an Iran-based bank for providing banking services to the IRGC-QF.

“We are targeting a vast network of front companies and individuals located in Iran, Turkey, and the UAE to disrupt a scheme the Iranian regime has used to illicitly move more than a billion dollars in funds,” said Treasury Secretary Steven T. Mnuchin.  “The IRGC, MODAFL, and other malign actors in Iran continue to exploit the international financial system to evade sanctions, while the regime funds terrorism and other destabilizing activities across the region.”  

“Central to this network and sanctioned today pursuant to our counterterrorism authority is Iran’s IRGC-controlled Ansar Bank and its currency exchange arm, Ansar Exchange, both of which used layers of intermediary entities to exchange devalued Iranian rial ultimately for dollars and euros to line the pockets of the IRGC and MODAFL.  This vast network is just the latest example of the Iranian regime’s use of deceptive practices to exploit the global financial system and divert resources to sanctioned entities,” said Treasury Under Secretary for Terrorism and Financial Intelligence Sigal Mandelker.  “This once again exposes to the international community the dangerous risks of operating in an Iranian economy that is deliberately opaque.”

ANSAR BANK’S SANCTIONS EVASION SCHEME

Through IRGC-controlled Ansar Bank, the Iranian regime established a layered network of front companies based in Iran, Turkey, and the UAE to bypass sanctions, gain access to the international financial system, and exchange devalued Iranian rial for dollars and euros. Ansar Bank also used international free zones to establish front companies. 

As part of this scheme, Ansar Bank used its Iran-based foreign currency arm, Ansar Exchange and its network, to convert Iranian rial ultimately to hundreds of millions of dollars and euros.  To provide this funding to Ansar Bank, MODAFL, and the IRGC, Ansar Exchange relied upon a network of front companies and agents in Turkey and the UAE.  In just the last year-and-a-half, four front companies- UAE-based Sakan General Trading, Lebra Moon General Trading, and Naria General Trading, as well as Iran-based Hital Exchange,  all designated today — provided the equivalent of approximately $800 million in funds to Ansar Exchange.  Additionally, Turkey-based Atlas Doviz acted as a secondary foreign currency provider for Ansar Exchange.  

These front companies are witting to Iran’s sanctions evasion. For example, as of 2019, Ansar Exchange Managing Director Alierza Atabaki worked closely with one central procurement agent, Reza Sakan, to avoid the scrutiny of Emirati authorities regarding Ansar Exchange’s financial dealings with UAE-based Sakan General Trading and other identified Ansar Exchange intermediaries.

Ansar Exchange network image

View the chart in Farsi describing Ansar Bank’s sanctions evasion scheme.

MODAFL, ANSAR BANK, AND ITS IRAN-BASED SUBSIDIARIES

MODAFL

MODAFL, first designated in 2007 pursuant to E.O. 13382 for supporting persons involved in Iran’s proliferation activities, supervises Iran’s development and production of missiles, including those used by Iran-backed Houthi militias in Yemen against coalition forces.  Today, OFAC designated MODAFL for providing logistic support to the IRGC-QF and its regional proxy groups.  Specifically, MODAFL was designated pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC-QF.

As of 2017, MODAFL used funds from the Central Bank of Iran (CBI) that were earmarked for the IRGC-QF.

 As a part of this scheme, multiple UAE-based firms were involved in the acquisition of hundreds of vehicles by MODAFL, an endeavor that also involved Iran-based Zagros Pardis Kish and Reza Heidari, who was designated pursuant to E.O. 13224 on November 20, 2017 for acting for or on behalf of, and for providing support to, the IRGC-QF as a part of a large-scale IRGC-QF counterfeiting ring.  Payment for these vehicles was made to Lebra Moon General Trading. Naria General Trading was also involved in the vehicle acquisition.

Ansar Bank and Ayatollah Ebrahimi

IRGC-controlled Ansar Bank was previously designated pursuant to E.O. 13382 in 2010. Today, OFAC designated Ansar Bank pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC-QF, and for being owned or controlled by the IRGC. With 1,081 branches throughout Iran, Ansar Bank procured hundreds of millions of dollars in the last three years on the IRGC’s behalf.

As recently as 2019, Ansar Bank officials maintained close associations with senior IRGC-QF officials and financial facilitators who use accounts at Ansar Bank to keep the equivalent of millions of dollars. For example, Treasury-designated IRGC-QF financial facilitator Meghdad Amini held funds at Ansar Bank.

Ansar Bank also extended the equivalent of millions of dollars as a loan to an IRGC-QF front company. IRGC-QF officials’ salaries also have been paid using Ansar Bank, and Ansar Bank is used by the IRGC-QF to pay the salaries of its foreign fighters, particularly those based in Syria. On October 16, 2018, Treasury designated two of these Syria-based, IRGC-QF-backed militias, the Fatemiyoun Division and Zainabiyoun Brigade, which are comprised of foreign fighters, including child soldiers as young as 14 years old.  

Ayatollah Ebrahimi, who was recruited into the IRGC at the age of 14, has been the managing director of Ansar Bank since 2005. In this capacity, Ebrahimi worked directly with IRGC-QF officials to facilitate their financial activities, including the conversion of euros or the UAE dirham for the terrorist group. Ayatollah Ebrahimi is being designated pursuant to E.O. 13224 for acting for or on behalf of Ansar Bank.

Treasury is also taking action against a number of Iranian firms owned, or under the control of, Ansar Bank. Specifically, Iranian Atlas Company, Ansar Bank Brokerage Company, and Ansar Information Technology are being designated pursuant to E.O. 13224 for being owned or controlled by Ansar Bank.

ANSAR EXCHANGE AND ITS NETWORK OF PROCUREMENT AGENTS

Ansar Exchange

Central to this foreign currency procurement network is Iran-based Ansar Exchange, which conducted significant volumes of foreign currency exchange services for sanctioned Iranian entities, including Ansar Bank, MODAFL, and the IRGC. Ansar Exchange is wholly owned and controlled by Ansar Bank.

Since 2016, Ansar Exchange conducted currency exchange services for Ansar Bank totaling over one billion dollars. Over the past few years, Ansar Exchange also directly provided MODAFL with the equivalent of approximately 100 million in dollars and euros, in addition to the equivalent of approximately 130 million dollars’ worth of goods and services ultimately destined for the benefit of the IRGC.

As recently as 2019, Ansar Exchange maintained a close association with senior IRGC-QF officials.  Ansar Exchange is being designated pursuant to E.O. 13224 for being owned or controlled by Ansar Bank, and for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Ansar Bank.  Ansar Exchange is also being designated for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC-QF, and for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC.

Alireza Atabaki

Alireza Atabaki is the managing director of Ansar Exchange. He co-owns Zagros Pardis Kish with Reza Heidari, an individual designated by Treasury in 2017 for acting for or on behalf of, and providing support to, the IRGC-QF. As recently as early 2019, Atabaki has worked with the IRGC-QF and coordinated transactions using an identified IRGC-QF front company. 

Alireza Atabaki is being designated pursuant to E.O. 13224 for acting for or on behalf of Ansar

Exchange.

In 2018, Iran-based Atlas Exchange — also designated today — at the behest of Atabaki, paid hundreds of thousands of euros and dirham to companies in Europe and the UAE. In 2018 and 2019, Atabaki worked closely with UAE-based Iranian financial facilitator Reza Sakan and UAE-based Mohammad Vakili, both of whom are being designated today. Vakili is affiliated with UAE-based companies Best Leader General Trading LLC and Golden Commodities General Trading LLC. Since at least 2015, Atabaki, in coordination with Iranian financial facilitator Assadollah Seifi, used Vakili and his UAE-based companies as foreign currency procurement and financial facilitation agents to procure and transfer millions of dollars, including in cash. 

Zagros Pardis Kish

Ansar Exchange’s Managing Director Atabaki and Reza Heidari are registered as the co-owners of Zagros Pardis Kish, a company that is wholly owned by Ansar Bank. Ansar Exchange lists Zagros Pardis Kish as one of its major foreign currency customers.  

Zagros Pardis Kish was involved in MODAFL’s acquisition of hundreds of vehicles shipped from the UAE to Iran. Multiple UAE-based firms were used to pay for and ship the vehicles.  Reza Heidari and Zagros Pardis Kish manager Iman Sedaghat were involved in this endeavor. Zagros Pardis Kish is being designated pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of MODAFL, and for being owned or controlled by Alireza Atabaki.

In his capacity as manager of Zagros Pardis Kish, Iman Sedaghat coordinated the purchase of the hundreds of vehicles for MODAFL through the UAE for millions of dollars. Iman Sedaghat was previously involved in working with the IRGC-QF. Iman Sedaghat is being designated pursuant to E.O. 13224 for acting for or on behalf of Zagros Pardis Kish, and for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, MODAFL.

UAE- AND TURKEY-BASED FRONT COMPANIES

Sakan General Trading and Reza Sakan

Among the UAE-based companies sanctioned today, UAE-based Sakan General Trading provided the most foreign currency exchange support to Ansar Exchange, and is owned by UAE resident and Iranian national Reza Sakan and his Iran-based firm Sakan Exchange, also known as Joint Partnership of Reza Sakan Dastgiri and Associates. Sakan General Trading was involved in financing the purchase of military aircraft tires by Iran’s Pars Aviation Service Company for the Syrian Air Force.

Sakan General Trading recently changed its name to Royal Credit General Trading.

Sakan General Trading is being designated pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Ansar Exchange. Reza Sakan is being designated pursuant to E.O. 13224 for being otherwise associated with Sakan General Trading, as he owns or controls Sakan General Trading. Sakan Exchange is also being designated pursuant to E.O. 13224 for being owned or controlled by Reza Sakan.

Hital Exchange and Seyyed Mohammad Reza Ale Ali

Hital Exchange, also known as Seyyed Mohammad Reza Ale Ali Currency Exchange, provided a significant volume of euros and dollars to Ansar Exchange. It is owned by Iranian national Seyyed Mohammad Reza Ale Ali who worked directly with Ansar Exchange Managing Director Alireza Atabaki to convert foreign currency.

From October 2016 to March 2018, Mohammad Reza Ale Ali, using Hital Exchange, provided Ansar Exchange with the equivalent of approximately $180 million in euro and U.S. dollar banknotes. 

Today, Mohammad Reza Ale Ali is being designated pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Ansar Exchange. Hital Exchange is also being designated pursuant to E.O. 13224 for being owned or controlled by Mohammad Reza Ale Ali.

Atlas Exchange and Mohammad Vakili

Ansar Exchange also used Iran-based Atlas Exchange and its brokers to procure foreign currency.  During the latter half of 2018, Ansar Exchange directed Atlas Exchange to transfer hundreds of thousands of euros and dirham to an Iranian company in the UAE and four companies in Europe. As of early 2019, Atlas Exchange solicited business with sanctioned Iranian banks. Atlas Exchange is being designated pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Ansar Exchange.

Atlas Exchange is owned by Mohammad Vakili, who resides in the UAE and collaborated with Assadollah Seifi to use two UAE-based companies – the Best Leader General Trading and Golden Commodities General Trading – to evade sanctions. Since at least 2015, Attabaki (Ansar Exchange’s managing director) in coordination with Assadollah Seifi used Vakili and his affiliated UAE-based companies, the Best Leader General Trading and Golden Commodities, to procure and transfer millions of dollars including in cash. The Best Leader General Trading recently changed its name to Wilmington General Trading.

As recently as late 2018, Atabaki (Ansar Exchange’s managing director) coordinated closely with Mohammad Vakili on financial matters. Vakili effectuated multiple transfers worth hundreds of thousands of dollars to entities in the UAE and Turkey on behalf of Atabaki, who has instructed Vakili to increase certain deposits for companies affiliated with the scheme. Mohammad Vakili is being designated pursuant to E.O. 13224 for acting for or on behalf of Alireza Atabaki.

Asadollah Seifi, Golden Commodities General Trading, and The Best Leader General Trading

Asadollah Seifi used UAE-based Golden Commodities, which is under his supervision, and UAE-based company The Best Leader General Trading, to obfuscate millions of dollars’ worth of transactions benefiting the Iranian regime. Seifi also manages Atlas Exchange, and his procurement of U.S. dollars involved the transfer of funds through U.S.-designated banks such as Bank Mellat and Europaisch-Iranische Handelsbank AG. In August 2018, Seifi also facilitated the purchase of gold by the Iranian regime after U.S. sanctions on Iranian gold had been reimposed.

Seifi has also facilitated the purchase of foreign currency for the IRGC.

Assadolah Seifi is being designated pursuant to E.O. 13224 for acting for or on behalf of Atlas Exchange.  Golden Commodities General Trading LLC is being designated pursuant to E.O. 13224 for being owned or controlled by Asadollah Seifi. The Best Leader General Trading is being designated pursuant to E.O. 13224 for being owned or controlled by Asadollah Seifi.

Suleyman Sakan and Atlas Doviz Ticaret A.S.

Since 2017, Turkey-based Suleyman Sakan, who is affiliated with Turkish firm Atlas Doviz Ticaret A.S., provided millions of U.S. dollars in foreign currency exchange services to Ansar Exchange, including through Turkey-based Atlas Doviz. Suleyman Sakan is an associate of Reza Sakan and UAE-based Sakan General Trading. Since at least 2017, Suleyman Sakan worked with Reza Sakan to expand their business activities to Oman using the Omani financial sector.  

Suleyman Sakan is being designated pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Ansar Exchange.

Atlas Doviz Ticaret A.S. is being designated pursuant to E.O. 13224 for being owned or controlled by Suleyman Sakan.

Ali Shams Mulavi

Since 2017, another Ansar Exchange intermediary agent, Turkey-based Iranian financial facilitator Ali Shams Mulavi, has used Naria General Trading to purchase foreign currency on behalf of Ansar Exchange. In 2019, Ali Shams Mulavi procured and transferred U.S. dollar banknotes for Ansar Exchange.

Ali Shams Mulavi is being designated pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Ansar Exchange.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of these targets that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.  OFAC’s regulations generally prohibit all dealings by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated persons.

In addition, persons that engage in certain transactions with the individuals and entities designated today may themselves be exposed to sanctions or subject to an enforcement action.  Furthermore, unless an exception applies, any foreign financial institution that knowingly facilitates a significant transactions for any of the individuals or entities designated today could be subject to U.S. sanctions.

Links:

OFAC Notice

Treasury Press Release

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March 26, 2019: SECO adds Tariq Gidar Group to counter terrorism sanctions

March 27, 2019, 6:15 am
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On Tuesday, Swiss authorities added the following entity:

SSID: 10-40270 Foreign identifier: QDe.160 Name: Tariq Gidar Group (TGG)

Good quality a.k.a.: a) Tehrik-e-Taliban-Tariq Gidar Group b) TTP-Tariq Gidar Group c) Tehreek-I-Taliban Pakistan Geedar Group d) TTP Geedar Group e) Tariq Geedar Group f) Commander Tariq Afridi Group g) Tariq Afridi Group h) Tariq Gidar Afridi Group i) The Asian Tigers Address: Afghanistan/ Pakistan border region

Relation: Splinter group of Tehrik-e Taliban Pakistan (TTP) (QE.T.132.11., SSID 10-17777) Other information: Splinter group of Tehrik-e Taliban Pakistan (TTP) (QDe.132). The group was formed in Darra Adam Khel, Federally Administered Tribal Area (FATA), Pakistan, in 2007. INTERPOL-UN Security Council Special Notice web link available. Modifications: Listed on 22 Mar 2019

to its Al-Qaida/bin Laden/Taliban counter terrorism sanctions program.

Links:

FINMA Notice

Data files of updates – PDF, XML

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HKMA Alert: Fraudulent United Overseas Bank websites

March 27, 2019, 6:15 am
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Press Releases

Fraudulent websites related to United Overseas Bank Ltd.

The Hong Kong Monetary Authority (HKMA) wishes to alert members of the public to a press release issued by United Overseas Bank Ltd. on fraudulent websites, which has been reported to the HKMA. Hyperlink to the press release is available on the HKMA website for ease of reference by members of the public.

Anyone who has provided his or her personal information to the websites concerned or has conducted any financial transactions through the websites should contact the bank concerned using the contact information provided in the press release, and report to the Police or contact the Cyber Security and Technology Crime Bureau of the Hong Kong Police Force at 2860 5012.

 

Hong Kong Monetary Authority
5 March 2019

Link:

HKMA Notice

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OFAC Enforcement Action: Hopefully, the 3rd time is the charm…

March 28, 2019, 6:35 am
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This is the third enforcement action just this year that is focused on oversight of subsidiaries… since this seems to be a pattern in enforcement, and since it’s against a name company (Stanley Black & Decker), I am posting this in full. You’ll see that it has hints of both the Kollmorgen Corporation and AppliChem GmbH actions:

Stanley Black & Decker, Inc. Settles Potential Civil Liability for Apparent Violations of the Iranian Transactions and Sanctions Regulations Committed by its Chinese-Based Subsidiary Jiangsu Guoqiang Tools Co. Ltd.:

Stanley Black & Decker, Inc. (“Stanley Black & Decker”), a company based in New Britain, Connecticut, on behalf of itself and its subsidiary located in China, Jiangsu Guoqiang Tools Co. Ltd. (“GQ”), has agreed to pay $1,869,144 to settle its potential civil liability for 23 apparent violations of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR). Specifically, between on or about June 29, 2013 and on or about December 30, 2014, GQ exported and attempted to export 23 shipments of power tools and spare parts, with a total value of $3,201,647.73, to Iran or to a third country with knowledge that such goods were intended specifically for supply, transshipment, or reexportation, directly or indirectly, to Iran, which would have been prohibited if engaged in by a U.S. person, under §§ 560.203 and 560.204 of the ITSR. These transactions appear to have violated § 560.215 of the ITSR (referred to hereafter as the “Apparent Violations”).

OFAC determined that Stanley Black & Decker voluntarily self-disclosed the Apparent Violations on behalf of GQ, and that the apparent violations constitute an egregious case. The statutory maximum civil monetary penalty amount for the Apparent Violations is $6,922,757, and the base civil monetary penalty amount for the Apparent Violations is $3,461,378.

Stanley Black & Decker began acquisition negotiations with GQ in 2011, during which it engaged in due diligence and discovered GQ exported to Iran. Stanley Black & Decker took steps to encourage GQ to cease sales to, and transactions with, Iran prior to the acquisition date and made ceasing such sales a prerequisite condition of the closing. GQ’s representatives agreed to these terms and conditions. In May 2013, Stanley Black & Decker acquired a 60 percent interest in GQ and created a joint venture with the firm.

Subsequent to its acquisition of GQ, Stanley Black & Decker provided a series of trainings to GQ’s employees on the company’s business conduct guidelines, the Foreign Corrupt Practices Act, and sanctions. Specifically, in early August 2013 a Stanley Black & Decker Global Trade Compliance for China employee reviewed the company’s trade compliance policies and procedures with GQ’s Manager for Export Sales by telephone. After this one training session, the individual who conducted the training asked the GQ Manager for Export Sales to provide the same training to her team within GQ, and to designate two members of her team to attend additional training on a customer screening tool. However, Stanley Black & Decker did not implement procedures to monitor or audit GQ’s operations to ensure that its Iran-related sales did not recur post-acquisition.

Despite the written agreements GQ’s senior management executed in which they attested that GQ would not engage in transactions with Iran, and notwithstanding the above-referenced trainings Stanley Black & Decker provided, GQ continued to export goods to Iran throughout 2013 and 2014. Once Stanley Black & Decker became aware of the potential violations of U.S. economic sanctions, it initiated an internal investigation, subsequently hired a third-party independent investigative company, and ultimately reported the matter to OFAC.

Stanley Black & Decker’s internal investigation determined various GQ board members and senior management participated in these activities with knowledge that such conduct violated its parent company’s policies and U.S. economic sanctions against Iran. These personnel and other GQ employees appear to have engaged in non-routine business practices in order to conceal and facilitate GQ’s prohibited exports to Iran. GQ utilized six trading companies as conduits for these sales — four companies located in the United Arab Emirates and two companies located in China. In addition, GQ employees created fictitious bills of lading with incorrect ports of discharge and places of delivery and instructed their customers not to write “Iran” on business documents, such as bills of lading.

For more information regarding the conduct that led to the apparent violations, please see the Settlement Agreement between OFAC and Stanley Black & Decker here.

The settlement amount reflects OFAC’s consideration of the following facts and circumstances, pursuant to the General Factors under OFAC’s Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

OFAC considered the following to be aggravating factors:

(1) GQ, and its senior management, including two board members and an export sales manager, willfully violated the ITSR when it exported and attempted to export, reexport, sell, or supply power tools and spare parts directly or indirectly to Iran with knowledge that such activities constituted apparent violations of U.S. economic sanctions regulations and laws;

(2) GQ caused harm to the objectives of the ITSR by conferring an economic benefit to Iran over an 18-month period, in a systematic scheme involving a series of transactions that occurred on a continuing basis; and

(3) GQ is a sophisticated company with a history of extensive export operations, with executive leadership who had knowledge of U.S. economic sanctions.

OFAC considered the following to be mitigating factors:

(1) Neither Stanley Black & Decker nor GQ have received a penalty notice or Finding of Violation from OFAC in the five years preceding the earliest transaction giving rise to the apparent violations;

(2) Upon learning of GQ’s apparent violations, Stanley Black & Decker implemented immediate and substantive remedial efforts, including halting all GQ exports, hiring an independent investigator; and

(3) Stanley Black & Decker cooperated with OFAC’s investigation by conducting an extensive investigation and producing the results to OFAC, responding to OFAC’s requests for additional information with detailed records and meaningful clarifications, and signed multiple tolling agreements to extend the statute of limitations.

Consistent with its Settlement Agreement with OFAC, Stanley Black & Decker has committed to enhancing GQ’s compliance procedures by ensuring that it has a management team in place that: (1) is committed to a culture of compliance; (2) conducts regular risk assessments to ensure that its internal controls appropriately mitigate the entity’s sanctions-related risks; (3) conducts regularized audits; and (4) provides ongoing sanctions compliance training throughout GQ.

This enforcement actions highlights the importance for U.S. companies to conduct sanctions- related due diligence both prior and subsequent to mergers and acquisitions, and to take appropriate steps to audit, monitor, and verify newly acquired subsidiaries and affiliates for OFAC compliance. U.S.-owned or -controlled foreign subsidiaries are subject to the ITSR and U.S. person parent companies may face potential exposure to civil monetary penalties vis-à-vis the actions of their foreign subsidiaries. Foreign acquisitions can pose unique risks that U.S. person parent companies need to address fully at all stages of its relationship with the subsidiary. U.S. parent companies are encouraged to take steps to mitigate risk to sanctions exposure, including by addressing known deficiencies like unconventional record-keeping practices, and any hindrances to monitoring, auditing, or investigating the foreign subsidiary’s operations. Testing of compliance procedures and timely auditing of subsidiaries can mitigate the risk of exposure to U.S. economic sanctions violations. For more information regarding OFAC regulations, please go to: http://www.treasury.gov/ofac.

Links:

OFAC Notice

OFAC Enforcement Information

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EU, OFSI synchronize the Tariq Gidar Group listing…

March 28, 2019, 8:28 am
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Earlier today, UK regulators updated the following listing:

1. TARIQ GIDAR GROUP (TGG)

a.k.a: (1) COMMANDER TARIQ AFRIDI GROUP (2) TARIQ AFRIDI GROUP (3) TARIQ GEEDAR GROUP (4) TARIQ GIDAR AFRIDI GROUP (5) TEHREEK-I-TALIBAN PAKISTAN GEEDAR GROUP (6) TEHRIK-E-TALIBAN-TARIQ GIDAR GROUP (7) THE ASIAN TIGERS (8) TTP GEEDAR GROUP (9) TTP-TARIQ GIDAR

GROUP Address: Afghanistan/Pakistan border region. Other Information: UN Ref: QDe.160. Splinter group of Tehrik-e Taliban Pakistan (TTP) (QDe.132). The group was formed in Darra Adam Khel, Federally Administered Tribal Area (FATA), Pakistan, in 2007. (Listing to be treated as temporary for 30 days from the date of listing by the UN or until the EU adds the new listing to an existing sanctions regulation (whichever is sooner) in accordance with Policing and Crime Act 2017). UN Listing (formerly temporary listing, in accordance with Policing and Crime Act 2017). Listed on: 25/03/2019 Last Updated: 25/03/2019 28/03/2019 Group ID: 13786

to reflect the passage of Commission Implementing Regulation (EU) 2019/507.

Links:

OFSI Notice

Commission Implementing Regulation (EU) 2019/507

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HKMA Alert: HSBC Phishing Email

March 29, 2019, 6:50 am
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Press Releases

Phishing email related to The Hongkong and Shanghai Banking Corporation Limited

The Hong Kong Monetary Authority (HKMA) wishes to alert members of the public to a press release issued by The Hongkong and Shanghai Banking Corporation Limited on phishing email, which has been reported to the HKMA.  Hyperlink to the press release is available on the HKMA website for ease of reference by members of the public.

Anyone who has provided his or her personal information to the email concerned or has conducted any financial transactions through the email should contact the bank concerned using the contact information provided in the press release, and report to the Police or contact the Cyber Security and Technology Crime Bureau of the Hong Kong Police Force at 2860 5012.

 

Hong Kong Monetary Authority
19 February 2019

Link:

HKMA Notice

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