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OFAC adds to Kingpin list

April 11, 2019, 8:18 am
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Earlier today, OFAC added the following person:

CHAMS, Kassem (a.k.a. CHAMS, Qassim Muhammed; a.k.a. SHAMS, Kassem Mohammed; a.k.a. SHAMS, Qasim Muhammed), Hermel, Lebanon; Chams Building, 3rd Floor Jalal, Chtaura, Zahle, Lebanon; DOB 20 Mar 1962; POB Lebanon; citizen Lebanon; Gender Male (individual) [SDNTK] (Linked To: CHAMS MONEY LAUNDERING ORGANIZATION; Linked To: CHAMS EXCHANGE COMPANY SAL).

and entities:

CHAMS EXCHANGE COMPANY SAL (a.k.a. ALI MOHAMED CHAMS & PARTNER; a.k.a. ALI MOHAMED CHAMS AND PARTNER; a.k.a. CHAMS EXCHANGE), Sahata Choutra, Chtaura, Lebanon; Chams Building, 3rd Floor, Jalal, Chtaura, Zahle, Lebanon [SDNTK]. 

 

CHAMS MONEY LAUNDERING ORGANIZATION (a.k.a. CHAMS MLO), Lebanon [SDNTK].

to its Kingpin Act counter narcotics trafficking sanctions.

And Treasury issued a press release about it:

Treasury Sanctions Lebanese Money Launderer Kassem Chams Who Moves Money on Behalf of Narcotics Trafficking Organizations and Hizballah

Washington – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) identified Lebanese national Kassem Chams and designated the Chams Money Laundering Organization as Specially Designated Narcotics Traffickers (SDNT) pursuant to the Foreign Narcotics Kingpin Designation Act (Kingpin Act).  OFAC also designated Chams Exchange, a money service business located in Chtaura, Lebanon.

OFAC also identified Kassem Chams and the Chams Money Laundering Organization as an affiliated network of Hizballah pursuant to the Hizballah International Financing Prevention Amendments Act (HIFPAA). 

“Kassem Chams and his international money laundering network move tens of millions of dollars a month in illicit narcotics proceeds on behalf of drug kingpins and facilitate money movements for Hizballah.  We are targeting the financial infrastructure of these narcotics traffickers as part of this administration’s unprecedented campaign to prevent Hizballah and its global terror affiliates from profiting off violence, corruption, and the drug trade,” said Sigal Mandelker, Under Secretary for Terrorism and Financial Intelligence. “Treasury continues to aggressively use its tools to cut off global support networks used by Hizballah to finance its nefarious activities.”

Lebanese narcotics money launderer Kassem Chams is the owner of Chams Exchange, which launders drug proceeds throughout the world on behalf of narcotics trafficking organizations and facilitates money movements for Hizballah.  Chams moves money to and from Australia, Colombia, Italy, Lebanon, the Netherlands, Spain, Venezuela, France, Brazil, and the United States as part of his narcotics money laundering activities.  The Chams Money Laundering organization moves tens of millions of dollars a month for designatednarcotics traffickers, such as the Colombian criminal group La Oficina De Envigado and Lebanese drug money launderer Ayman Said Joumaa.  Joumaa was designated under the Kingpin Act in 2011 for laundering the proceeds of narcotics-related and other illicit activities—as much as $200 million per month—through various channels, including bulk cash smuggling operations and Lebanese money exchange houses.  Joumaa’s network is also linked to financing Hizballah.  La Oficina de Envigado was designated under the Kingpin Act in 2014.  Operatives for La Oficina play a major role in organized criminal activity, including narcotics trafficking, both within and outside of Colombia.  Transnational criminal groups from outside of Colombia, including Mexico’s Sinaloa Cartel, have come to rely upon operatives of La Oficina for support in trafficking narcotics throughout the world.

These OFAC sanctions are part of a joint effort with DEA’s Project Cassandra, which targets Hizballah’s global criminal support networks that operate as a logistics, procurement and financing arm for Hizballah and which are involved in the global movement of large quantities of narcotics and proceeds from narcotics sales.  The DEA has determined that the Chams Money Laundering Organization launders a large portion of drug proceeds through Lebanon, which also benefits Hizballah.

The Chams Exchange operates under license and the supervision of the Central Bank of Lebanon (BdL) despite U.S authorities long suspecting it of being a significant third party money laundering operation.  Treasury is committed to working with BdL to eliminate access to the Lebanese financial system by narcotics traffickers, money launderers, and terrorist groups such as Hizballah. 

Today’s OFAC designations were conducted in coordination with the DEA Special Operations Division’s Counter Narco-Terrorism Operations Center, the DEA New Jersey Division, and the DEA Office of Global Enforcement, with assistance from the Treasury Department’s Financial Crimes Enforcement Network. 

Today’s actions are part of ongoing efforts under the Kingpin Act to apply financial measures against significant foreign narcotics traffickers and their financial associates worldwide.  Since June 2000, more than 2,100 entities and individuals have been named pursuant to the Kingpin Act for their role in international narcotics trafficking.  Penalties for violations of the Kingpin Act range from civil penalties of up to $1,466,485 per violation to more severe criminal penalties.  Criminal penalties for corporate officers may include up to 30 years in prison and fines up to $5 million.  Criminal fines for corporations may reach $10 million.  Other individuals could face up to 10 years in prison and fines pursuant to Title 18 of the United States Code for criminal violations of the Kingpin Act.

The Treasury Department continues to prioritize disruption of the full range of Hizballah’s illicit financial activity and has designated more than 40 Hizballah-affiliated individuals and entities since 2017.

As a result of today’s actions, any assets of the designated individual or entities in the United States or in the possession or control of a U.S. person must be blocked and 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 persons.

Links:

OFAC Notice

Treasury Press Release

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EU, OFSI remove Iraqi entities

April 11, 2019, 8:48 am
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Earlier today, UK officials implemented Commission Implementing Regulation (EU) 2019/567 by removing the following entities:

1. GENERAL ESTABLISHMENT FOR THARTHAR PROJECT

Address: PO Box 21, Fallouja, Iraq. Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 11/04/2019 Group ID: 8099.

2. IRAQI BROADCASTING AND TELEVISION ESTABLISHMENT

Address: Broadcasting and TV Building, Salihiya, Karkh, Baghdad, Iraq. Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 11/04/2019 Group ID: 8110.

3. IRAQI NEWS AGENCY

Address: 28 Nissan Complex, Al Salihiya, Baghdad, Iraq. Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 11/04/2019 Group ID: 8116.

4. MINISTRY OF YOUTH, DIRECTORATE GENERAL OF PLANNING AND FOLLOW UP, IMPORT SECTION

Address: PO Box 19055, Palestine Street, near Al-Shaab Stadium, Baghdad, Iraq. Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 11/04/2019 Group ID: 8131.

5. STATE ENTERPRISE FOR IRRIGATION PROJECTS

Address: Karantina, near Sarafiya Bridge, Baghdad, Iraq. Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 11/04/2019 Group ID: 8184.

6. STATE ESTABLISHMENT OF HADITHA DAM

Address: Haklanya, Haditha, Iraq. Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 11/04/2019 Group ID: 8210.

7. STATE ESTABLISHMENT OF HEMREEN DAM

Address: 6 Mukdadiya, Mukdadiya, Iraq. Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 11/04/2019 Group ID: 8211.

8. STATE ESTABLISHMENT OF MOSUL DAM

Address: Ninewa Governorate, Mosul, Iraq. Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 11/04/2019 Group ID: 8215.

9. STATE ESTABLISHMENT OF SMALL DAMS AND REGULATORS

Address: Sinak, Baghdad, Iraq. Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 11/04/2019 Group ID: 8216.

from its Iraq sanctions program.

Links:

OFSI Notice

Commission Implementing Regulation (EU) 2019/567

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Two persons removed from EU, UK Syria sanctions

April 11, 2019, 8:57 am
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Due to a January 31 judgment from the General Court of the European Union (published in the Official Journal on March 18), the following person:

ABDULKARIM Wael

DOB: 30/09/1973. POB: Danascus, Syria a.k.a: AL KARIM, Wael Address: Al Karim for Trade and Industry, PO Box 111, Damascus, Syria, 5797.Other Information: Leading businessperson of Palestinian origin operating In Syria in the oil, chemicals and manufacturing industries. Specifically, he represents Abdulkarim Group, a.k.a Al Karim Group/AlKarim for Trade and Industry/Al Karim Trading and Industry/Al Karim for the Trade and Industry. Abdulkarim Group is a leading manufacturer of lubricants, greases and industrial chemicals in Syria. Listed on: 09/03/2015 Last Updated: 18/03/2019 11/04/2019

Group ID: 13230.

and entity:

ABDULKARIM GROUP

a.k.a: (1) Al Karim for Trade and Industry (2) Al Karim Group Address: 5797 , Damascus, Syria.Other Information: An internationally recognised Syrian conglomerate associated with Wael Abdulkarim who is listed as a leading business person operating in Syria Listed on: 11/07/2017 Last Updated: 11/07/2017 11/04/2019 Group ID: 13492.

have been removed from the EU and UK Syria sanctions program.

Links:

OFSI Notice

Court Judgements: Mouhamad Wael Abdulkarim, Abdulkarim Group

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Under the sea… Acteon settles for multiple sets of violations

April 12, 2019, 6:05 am
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OFAC Notice:

Settlement Agreements between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Acteon Group, Ltd., 2H Offshore Engineering Ltd., KKR & Co. Inc., and Seatronics Ltd.

4/11/2019

 

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $227,500 settlement with Acteon Group Ltd. (“Acteon”), and Acteon’s subsidiary 2H Offshore Engineering Ltd. (“2H Offshore”) that has two Malaysian affiliates: 2H Offshore Engineering Sdn Bhd and 2H Offshore Engineering (Asia Pacific) Sdn Bhd (collectively “2H KL”).  Acteon, a subsea service provider in the oil and gas industry based in the United Kingdom (UK), and 2H Offshore, an engineering contractor based in the UK that specializes in services used in offshore oil and gas drilling production, have agreed to settle their potential civil liability for seven apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. part 515 (CACR).  Specifically, between on or about May 18, 2011 and on or about October 18, 2012, 2H KL performed engineering design analyses for oil well drilling projects in Cuban territorial waters, and sent its engineers to Cuba to conduct workshops on these analyses.  OFAC determined that 2H Offshore voluntarily self-disclosed the apparent violations, and that these apparent violations constitute an egregious case.

 

Separately, OFAC announced a $213,866 settlement with KKR & Co. Inc. (“KKR”), Acteon, and Acteon’s subsidiaries Seatronics Ltd., Seatronics, Inc., and Seatronics Ptd. Ltd. (collectively “Seatronics”).  Acteon has agreed to settle: (1) it and Seatronics’, a geophysical services company based in the UK, potential civil liability for 13 apparent violations of the CACR; and (2) KKR’s, a global investment firm based in New York City, potential civil liability for three apparent violations of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR).  Specifically, between on or about August 12, 2010 and on or about March 16, 2012, Acteon appears to have violated § 515.201 of the CACR when Seatronics rented or sold equipment for oil exploration projects in Cuban territorial waters, and sent company engineers to service equipment on vessels operating in Cuban territorial waters.  In addition, between on or about September 10, 2014 and on or about November 11, 2014, Seatronics appears to have violated §§ 560.215 and § 560.204 of the ITSR when Seatronics Ltd.’s Abu Dhabi, United Arab Emirates branch rented or sold equipment to customers who appear to have embarked the equipment on vessels that operated in Iranian territorial waters.  OFAC determined that Acteon voluntarily self-disclosed the apparent violations, and that these apparent violations constitute a non-egregious case.

This gets pretty dense but, ultimately, jurisdiction hinges in the 2H-related violations because a US investment firm held a majority stake, and in the Seatronics case by KKR (another investment firm). In the latter case, the Seatronics firm was also Texas-based, so there would have been jurisdiction there as well.

Mr. Watchlist notes that the jurisdictional nexus is not clear in the Enforcement Information until you get we’ll into the document – it’s much clearer in OFAC”s Notice on its Recent Actions page.

The 2H violations were egregious, but self-disclosed – the base penalty of $227,500 was also what was meted out. In the Seatronics case, the settlement amount of $213,866 for self-reported, non-egregious violations was a small reduction from the base of $237,629.

Regarding the 2H violations:

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 determined the following to be aggravating factors: (1) 2H Offshore’s Global Director and 2H KL’s Technical Director willfully violated U.S. sanctions laws and regulations when they knowingly dealt with Cuban interests despite prior notification of their unlawfulness, and did so in at least one case with the knowledge and approval of Acteon; (2) 2H Offshore demonstrated reckless disregard for U.S. sanctions laws and regulations by failing to exercise a minimal degree of caution or care when it knowingly provided services or personnel for projects in Cuba; (3) senior 2H Offshore and 2H KL managers deliberately concealed their dealings with Cuba on multiple occasions; (4) 2H Offshore engaged in a pattern or practice of conduct that led to the Apparent Violations and spanned several years; (5) 2H Offshore and 2H KL’s senior managers had actual knowledge of the business activity involving Cuba, in addition to Acteon’s Finance Director in one instance; (6) 2H Offshore’s compliance program, established by Acteon, was ineffective, and 2H Offshore failed to adhere to the sanctions compliance guidance Acteon issued in 2007 to all of its businesses that specifically prohibited dealings with Cuba even through third countries; (7) 2H Offshore’s conduct harmed U.S. foreign policy objectives by providing economic benefit to the Government of Cuba, and supported its efforts to extract or exploit valuable natural resources; and (8) 2H Offshore and Acteon are sophisticated international businesses that were aware of the applicable U.S. sanctions laws and regulations.

OFAC determined the following to be mitigating factors: (1) 2H Offshore and Acteon voluntarily submitted information to OFAC, were responsive to follow-up questions, and agreed to toll the statute of limitations on three occasions; and (2) 2H Offshore and Acteon took remedial steps including undertaking appropriate disciplinary actions with respect to the 2H Offshore personnel involved with the Apparent Violations, providing compliance training, and implementing a new sanctions compliance program that includes procedures for elevating issues for review.

Additionally, Acteon and 2H Offshore have confirmed to OFAC that they have terminated the conduct that led to the Apparent Violations, and have taken the following steps to minimize the risk of recurrence of similar conduct in the future:

 Acteon has taken appropriate disciplinary actions with respect to the 2H Offshore personnel who were involved with the Apparent Violations and has provided new sanctions compliance training.

 Acteon’s Head of Trade Compliance and outside counsel have conducted sanctions and export compliance training for each 2H Offshore office. 2H Offshore will continue to conduct export compliance training tailored to its business model. Additionally, written guidelines on U.S. sanctions and export restrictions have been distributed to Acteon’s operating companies.

 2H Offshore has implemented new procedures and processes, including an automated project proposal management process that includes customer screening (including customer billing location), location screening (including field development locations), and screening of new service projects before a new project can be actioned.

 2H Offshore is developing a compliance audit process, including appropriate mechanisms for reporting audit findings and implementing corrective actions. Acteon is assigning appropriate personnel with responsibility for monitoring and periodically assessing 2H Offshore’s compliance with applicable export control and sanctions laws and reporting the results of such assessment. Acteon has appointed a Head of Trade Compliance with responsibility for monitoring and ensuring 2H Offshore’s ongoing compliance, and a Group General Counsel who will provide ultimate oversight of the compliance monitoring function.

And the Seatronics violations:

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 determined the following to be aggravating factors:

(1) Seatronics demonstrated reckless disregard for U.S. sanctions laws and regulations by failing to exercise a minimal degree of caution or care when it provided goods and services to vessels or persons that ultimately operated in Cuban and Iranian territorial waters; (2) Seatronics engaged in a pattern or practice of conduct that led to Apparent Violations of the CACR and the ITSR over the course of several years; (3) Seatronics’ senior management had actual knowledge of the business activity involving Cuba and should have known about the Iran-related risks associated with business activity involving the two UAE companies; (4) Acteon’s compliance program with respect to the apparent Cuba and Iran violations was, at a working-level, ineffective and Seatronics failed to adhere to the internally distributed sanctions compliance guidance issued in 2007 and 2013 to all of Acteon’s affiliates that specifically prohibited dealings with Cuba or Iran, respectively, including explicitly prohibiting such dealings through third countries or third persons; (5) Seatronics’ conduct harmed U.S. foreign policy objectives by supporting the efforts of the Government of Cuba and the Government of Iran to extract and exploit highly valuable natural resources, namely oil and gas; and (6) Acteon is a sophisticated international business operating in a high-risk industry that was aware of the applicable U.S. sanctions laws and regulations; likewise KKR is a sophisticated and internationally active company.

OFAC determined the following to be mitigating factors: (1) Acteon voluntarily submitted information to OFAC, was responsive to follow-up questions, and provided substantial cooperation, including by agreeing to toll the statute of limitations on three occasions; (2) Acteon stated it took remedial steps, including undertaking appropriate disciplinary actions with respect to the Seatronics managers who were involved in the exportation of goods or services to vessels operating in Cuban and Iranian territorial waters and providing compliance training; and (3) Acteon, Seatronics, and KKR have not received a Penalty Notice or Finding of Violation in the five years preceding the date of the earliest transaction giving rise to the Apparent Violations.

Additionally, Seatronics has confirmed to OFAC that they have terminated the conduct that led to the Apparent Violations, Acteon has agreed to exercise oversight of Seatronics, and both Acteon and Seatronics have taken the following steps to minimize the risk of recurrence of similar conduct in the future:

 Acteon has taken appropriate disciplinary actions with respect to the Seatronics personnel who were involved with the Apparent Violations.

 Acteon’s Head of Trade Compliance and outside counsel have conducted sanctions and export compliance training for each Seatronics office. Seatronics will continue to conduct export compliance training tailored to its business model. Additionally, written guidelines on U.S. sanctions and export restrictions have been distributed to Acteon’s operating companies.

 Seatronics has implemented new procedures and processes, including customer screening and Ultimate Destination/End-User/End-Use Forms.

 Seatronics is developing a compliance audit process, including appropriate mechanisms for reporting audit findings and implementing corrective actions. Acteon is assigning appropriate personnel with responsibility for monitoring and periodically assessing Seatronics’ compliance with applicable export control and sanctions laws and reporting the results of such assessment to appropriate senior-level officials. Acteon has appointed a U.S. Trade Compliance Manager with responsibility for monitoring and ensuring Seatronics’ ongoing compliance, and a Group General Counsel who will provide ultimate oversight of the compliance monitoring function.

The lessons learned? Both settlements have identical concluding sections:

This enforcement action highlights the importance of: (1) implementing risk-based controls, such as regular audits, to ensure subsidiaries are complying with their obligations under OFAC’s sanctions regulations; (2) performing heightened due diligence, particularly with regard to affiliates, subsidiaries, or counter-parties known to transact with OFAC-sanctioned countries or persons, or that otherwise pose high risks due to their geographic location, customers, or suppliers, or products and services they offer; and (3) appropriately responding to derogatory information regarding the sanctions compliance efforts of persons subject to the jurisdiction of the United States.

Links:

OFAC Notice

OFAC Enforcement Information

OFAC Settlement Agreement (2H Offshore Violations)

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HKMA Alert: Hong Leong Bank phishing email

April 12, 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
22 March 2019

Link:

HKMA Notice

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New TAFA Quarterly Report is out

April 12, 2019, 8:09 am
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The UK publishes a quarterly report about its counter-terrorism sanctions program – and the one for Q4 of 2018 (calendar) is out. Here are the highlights:

  • At the end of the quarter, 9,000 GBP was frozen under TAFA, 18,000 under EU Reg 2580/2001, and 70,000 under the ISIL/Al-Qaida regime (EU Reg 881/2002). These represent 6 TAFA accounts or payments, 3 for EC 2580/2001 and 36 for ISIL-AQ. One item was frozen during the quarter under ISIL-AQ.
  • There were 3 new ISIL-AQ designations during the quarter and one new one under EU Reg 2016/1686 .
  • There were 5 TAFA renewals during the quarter
  • Under the ISIL-AQ regime, 8 licenses were issued during the quarter. And there are still 4 active General Licenses.

Link:

TAFA October-December 2018 Report

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Off to Hollywood!

April 14, 2019, 8:45 am
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Mr. Watchlist’s professional persona will be at the Dow Jones booth at the ACAMS spring conference (the official title would give me carpal tunnel if I typed it all) this Monday through Wednesday. As usual, it’s being held at the Diplomat resort hotel (it’s a Hilton – yay!) in Hollywood, Florida. Come say hi and we can chat about sanctions till the cows come home (although I’m not sure there are any cows down by Fort Lauderdale).

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March 26, 2019: HK SFC AML/CFT Circular

April 15, 2019, 6:05 am
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Circular to Licensed Corporations and Entities

Anti-Money Laundering / Counter-Financing of Terrorism

(1)  United Nations (Anti-Terrorism Measures) Ordinance

(2)  United Nations Sanctions (ISIL and Al-Qaida) Regulation

(1)  United Nations (Anti-Terrorism Measures) Ordinance 

Further to our circular issued on 14 March 2019, an updated list specifying terrorists and terrorist associates designated by the United Nations Security Council (“UNSC”) was published under section 4 of the United Nations (Anti-Terrorism Measures) Ordinance (“the UNATMO”) (Cap. 575) in the Gazette (G.N. (E.) 13 of 2019) on 25 March 2019.  A relevant press release issued by the UNSC, reflecting the updates since the previous list was published in the Gazette (G.N. (E.) 11 of 2019), is attached in Attachment 1 Note 1.

The aforesaid list can be found on the Government’s website (https://www.gld.gov.hk/egazette/pdf/20192313e/egn2019231313.pdf).

(2)  United Nations Sanctions (ISIL and Al-Qaida) Regulation 

Further to our circular issued on 14 March 2019, an updated list specifying “individuals, groups, undertakings and entities” was published under section 25 of the United Nations Sanctions (ISIL and Al-Qaida) Regulation (Cap. 537CB) on the website of the Commerce and Economic Development Bureauon 23 March 2019. A relevant press release issued by the UNSC, reflecting the updates since the previous list was published on the website of the Commerce and Economic Development Bureau, is attached in Attachment 1 Note 1.

The aforesaid list obtained from the website of the Commerce and Economic Development Bureau is attached in Attachment 2.

Licensed corporations (“LCs”) and associated entities (“AEs”) are reminded to refer to Chapter 6 of the Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Licensed Corporations) (“AML Guideline”) which contains guidance on the appropriate measures that LCs and AEs should take to ensure compliance with the regulations made under the UNATMO (Cap. 575) and the United Nations Sanctions Ordinance (Cap.537) Note 2.  The Securities and Futures Commission expects all new designations to be screened by LCs and AEs against their client lists as soon as practicable whenever there are updates.  LCs and AEs are also reminded to report any transactions or relationships they have or have had with any designated person or entity to the Joint Financial Intelligence Unit.

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

Links:

HK SFC Notice

HK SFC Circular

UN Press Releases (Attachment 1)

Commerce and Economic Development Bureau List (Attachment 2)

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April 12, 2019: OFAC sanctions Cuba-Venezuela oil commerce

April 15, 2019, 6:20 am
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On Friday, OFAC sanctioned the following entities:

JENNIFER NAVIGATION LIMITED (a.k.a. JENNIFER NAVIGATION LTD.), 80 Broad Street, Monrovia, Liberia; Identification Number IMO 4098018 [VENEZUELA-EO13850]. 

 

LARGE RANGE LIMITED, 80 Broad Street, Monrovia, Liberia; Identification Number IMO 6002286 [VENEZUELA-EO13850]. 

 

LIMA SHIPPING CORPORATION (a.k.a. LIMA SHIPPING CORP), 80 Broad Street, Monrovia, Liberia; Identification Number IMO 4063640 [VENEZUELA-EO13850]. 

 

PB TANKERS S.P.A. (a.k.a. PB TANKERS SPA), Via Principe di Belmonte 55, Palermo PA 90139, Italy; Via Jacopo Peri 1, Rome RM 00198, Italy; Website http://www.pbtankers.com; Email Address info@pbtankers.com; Identification Number IMO 5161787 [VENEZUELA-EO13850].

and cargo vessels:

ALBA MARINA Floating Storage Tanker Italy flag; Vessel Registration Identification IMO 9151838 (vessel) [VENEZUELA-EO13850] (Linked To: PB TANKERS S.P.A.). 

 

GOLD POINT Chemical/Oil Tanker Malta flag; Vessel Registration Identification IMO 9506693 (vessel) [VENEZUELA-EO13850] (Linked To: PB TANKERS S.P.A.). 

 

ICE POINT Chemical/Oil Tanker Italy flag; Vessel Registration Identification IMO 9379337 (vessel) [VENEZUELA-EO13850] (Linked To: PB TANKERS S.P.A.). 

 

INDIAN POINT Chemical/Oil Tanker Malta flag; Vessel Registration Identification IMO 9379325 (vessel) [VENEZUELA-EO13850] (Linked To: PB TANKERS S.P.A.). 

 

IRON POINT Chemical/Oil Tanker Malta flag; Vessel Registration Identification IMO 9388209 (vessel) [VENEZUELA-EO13850] (Linked To: PB TANKERS S.P.A.). 

 

NEDAS Crude Oil Tanker Greece flag; Vessel Registration Identification IMO 9289166 (vessel) [VENEZUELA-EO13850] (Linked To: JENNIFER NAVIGATION LIMITED). 

 

NEW HELLAS Crude Oil Tanker Greece flag; Vessel Registration Identification IMO 9221891 (vessel) [VENEZUELA-EO13850] (Linked To: LIMA SHIPPING CORPORATION). 

 

SILVER POINT Chemical/Oil Tanker Malta flag; Vessel Registration Identification IMO 9510462 (vessel) [VENEZUELA-EO13850] (Linked To: PB TANKERS S.P.A.). 

 

S-TROTTER Oil Products Tanker Panama flag; Vessel Registration Identification IMO 9216547 (vessel) [VENEZUELA-EO13850] (Linked To: LARGE RANGE LIMITED).

under its Venezuela sanctions program.

The Treasury Department:

Treasury Increases Pressure on Cuba to End Support to Maduro by Imposing Further Oil Sector Sanctions

Washington – Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated four companies that operate in the oil sector of the Venezuelan economy, pursuant to E.O. 13850, as amended.  Additionally, OFAC identified nine vessels, some of which transported oil from Venezuela to Cuba, as blocked property owned by the four companies.  The United States is continuing to take strong action against the illegitimate regime of former President Nicolas Maduro, to include those that prop up Maduro’s regime and contribute to Venezuela’s humanitarian crisis.

“We continue to target companies that transport Venezuelan oil to Cuba, as they are profiting while the Maduro regime pillages natural resources.  Venezuela’s oil belongs to the Venezuelan people, and should not be used as a bargaining tool to prop up dictators and prolong oppression,” said Treasury Secretary Steven T. Mnuchin.  “Maduro relies on the support he receives from the Cuban military and intelligence services to retain his hold on power because he does not have the support of the Venezuelan people.”

Today’s action further targets Venezuela’s oil sector, which continues to provide a lifeline to the illegitimate regime of former President Maduro:
 

  • Jennifer Navigation Limited is based in Monrovia, Liberia, and is the registered owner of Nedas.
    • Nedas is a crude oil tanker (IMO: 9289166) that delivered crude oil from Venezuela to Cuba during January and March of 2019.
  • Lima Shipping Corporation is based in Monrovia, Liberia, and is the registered owner of New Hellas.
    • New Hellas is a crude oil tanker (IMO: 9221891) that delivered crude oil from Venezuela to Cuba during February and March 2019.
  • Large Range Limited is based in Monrovia, Liberia, and is the registered owner of
    S-Trotter.
    • S-Trotter is an oil products tanker (IMO: 9216547) that delivered oil products from Venezuela to Cuba during February and March 2019.
  • PB Tankers S.P.A. is based in Italy, and is the registered owner of several vessels, including Silver Point, Alba Marina, Gold Point, Ice Point, Indian Point, and Iron Point.
    • Silver Point is a chemical and oil tanker (IMO: 9510462) that delivered oil products from Venezuela to Cuba during March 2019.
    • Alba Marina is a floating storage tanker (IMO: 9151838).
    • Gold Point is a chemical and oil tanker (IMO: 9506693).
    • Ice Point is a chemical and oil tanker (IMO: 9379337).
    • Indian Point is a chemical and oil tanker (IMO: 9379325).
    • Iron Point is a chemical and oil tanker (IMO: 9388209).
       

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,” FIN-2017-A003, “Advisory to Financial Institutions and Real Estate Firms and Professionals” and FIN-2018-A003, “Advisory on Human Rights Abuses Enabled by Corrupt Senior Foreign Political Figures and their Financial Facilitators.”

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 the designated entities, 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.

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 illegitimate Maduro regime, and combat corruption in Venezuela.

and State Department:

The United States Takes Action To End Cuba’s Malign Influence on Venezuela

Media Note

Office of the Spokesperson

Washington, DC

April 12, 2019

Today, the United States sanctioned four companies for operating in the oil sector of the Venezuelan economy and identified nine vessels as blocked property, pursuant to Executive Order 13850. These actions are a follow-on to the designations announced on April 5, which targeted entities and vessels known to be involved in the transportation of crude oil from Venezuela to Cuba.

Venezuela’s ongoing democratic transition is being impeded by malign actors that continue to prop up the former Maduro regime. Venezuelans lack access to basic necessities, such as water, electricity and adequate health care, while Maduro and his cronies continue to enrich themselves and strip Venezuela of its natural assets.

These actions seek to hinder the regime’s further theft and the predatory influence of Cuba, which takes Venezuela’s oil and pays the regime with security and intelligence forces to keep Nicolas Maduro in power.

The United States will continue to do all we can to stand up against Cuba’s support for the former Maduro regime and its hostility to the Venezuelan people’s aspiration to a peaceful, prosperous, democratic future. Cuba’s intervention only seeks to delay the inevitable—the peaceful transition back to freedom and democracy that is underway in Venezuela, led by the Venezuelan people, Interim President Juan Guaido, and the National Assembly.

issued press releases as well.

Links:

OFAC Notice

Treasury Press Release

State Department Press Release

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April 15, 2019: OFAC adds to counter terrorism sanctions (including FTO)

April 16, 2019, 6:00 am
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On Monday, OFAC added the following persons:

ALI, Halima Adan, Mombasa, Kenya; Nairobi, Kenya; DOB 10 Oct 1986; nationality Kenya; Gender Female; Passport A1659348 (Kenya); Kenyan ID No. 25142129; alt. Kenyan ID No. 22536936; alt. Kenyan ID No. 30760317; alt. Kenyan ID No. 22645786 (individual) [SDGT].

AL-RAWI, Abd-al-Rahman ‘Ali Husayn al-Ahmad (a.k.a. AL RAWI, Abdulrahman; a.k.a. AL-RAWI, Abd-al-Rahman; a.k.a. AL-RAWI, Abdul Rahman; a.k.a. AL-RAWI, Abu Abd Al Rahman), Turkey; DOB 1983; POB Albu Kamal, Dayr az Zawr Province, Syria; nationality Syria; Gender Male; Phone Number 905515983567; alt. Phone Number 9647718635788; alt. Phone Number 96351667406; alt. Phone Number 9647715959705 (individual) [SDGT].

AL-RAWI, Muhammad Abd-al-Qadir Mutni Assaf (a.k.a. MATNEE, Mohammed Abdulqader; a.k.a. MATNI, Muhammad ‘Abd-al-Qadir; a.k.a. MUTNI, Mohammad Abdul Kadir; a.k.a. MUTNI, Muhammad Abdul Qadar; a.k.a. “ABD-AL-QARIM, Abu”), Erbil, Iraq; DOB 15 Apr 1983; Gender Male; Passport G2590897 (individual) [SDGT].

AL-RAWI, Muhannad Mushtaq Talib Zghayir Karhout (a.k.a. TALIB, Mohanad M.; a.k.a. TALIB, Muhannad Mushtaq; a.k.a. ZUGHAYAR, Muhanad Mushtaq; a.k.a. ZUGHAYAR, Muhanad Mushtaq Talib), Baghdad, Iraq; Samsun, Turkey; DOB 26 Dec 1996; POB Al-Qa’im, Iraq; nationality Iraq; Email Address mohand.alrawii@gmail.com; Gender Male; Phone Number 9647821757598; National Foreign ID Number 00167950 (Iraq) (individual) [SDGT].

AL-RAWI, Mushtaq Talib Zughayr (a.k.a. AL-HASHIMI, Mushtaq Talib Zughayar Karhut; a.k.a. AL-RAWI, Abu Mus’ab; a.k.a. AL-RAWI, Mushtaq; a.k.a. AL-RAWI, Mushtaq Talib; a.k.a. AL-RAWI, Mushtaq Talib Zaghayir), Turkey; Belgium; DOB 1964; alt. DOB 1969; Gender Male; Phone Number 905537471039 (individual) [SDGT].

AL-RAWI, Umar Talib Zughayr (a.k.a. AL-HASHIMI, Umar Talib Zughayr; a.k.a. AL-RAWI, ‘Umar Talib; a.k.a. AL-RAWI, Umar Talib Zughayr Karhoot; a.k.a. ZGHYR, ‘Umr Talib; a.k.a. “AL-RAWI, Abu Umar”), Samsun, Turkey; al-Qa’im, Anbar Province, Iraq; Mersin Province, Turkey; DOB 1970; alt. DOB 1971; POB Iraq; nationality Iraq; Gender Male; Phone Number 907816941101; alt. Phone Number 9647734097694 (individual) [SDGT].

AL-RAWI, Walid Talib Zughayr (a.k.a. AL-HASHIMI, Walid Talib Zughayr; a.k.a. AL-RAWI, Waleed Talib Zghayir Karhout; a.k.a. ZGHAIR, Waleed Talib Zghair; a.k.a. ZGHYR, Walid Talib; a.k.a. “AL-RAWI, Abu Khalid”), Baghdad, Iraq; DOB 11 Nov 1988; nationality Iraq; Email Address waleed198811@gmail.com; Gender Male; Phone Number 9647807890955; alt. Phone Number 96407707840824; alt. Phone Number 9647720364973; Passport A11071541 (individual) [SDGT].

and entities:

AL-ARD AL-JADIDAH MONEY EXCHANGE COMPANY (a.k.a. AL ARDH AL JADIDA; a.k.a. AL-ARDH AL-JADEEDA EXCHANGE COMPANY; a.k.a. NEW LAND MONEY EXCHANGE COMPANY), Iraq; Hajin, Dayr az Zawr Province, Syria; Sanliurfa, Turkey; Phone Number 9647807798905; alt. Phone Number 964805611259; alt. Phone Number9647905886647 [SDGT].

IRGC GROUND FORCES (a.k.a. ISLAMIC REVOLUTION GUARDS CORPS GROUND FORCE), Tehran, Iran; Syria; Additional Sanctions Information – Subject to Secondary Sanctions [FTO] [IRGC].

IRGC NAVY (a.k.a. ISLAMIC REVOLUTION GUARDS CORPS NAVAL FORCE), Tehran, Iran; Syria; Additional Sanctions Information – Subject to Secondary Sanctions [FTO] [IRGC]. 

to different counter terror sanctions programs. Note that the IRGC designations have the FTO program tag, in addition to the SDGT tag.

In addition, the following designations were updated:

BASIJ RESISTANCE FORCE (a.k.a. BASEEJ; a.k.a. BASIJ; a.k.a. BASIJ-E MELLI; a.k.a. MOBILIZATION OF THE OPPRESSED ORGANIZATION; f.k.a. SAZMAN BASIJ MELLI; a.k.a. SAZMAN-E MOGHAVEMAT-E BASIJ; f.k.a. VAHED-E BASIJ-E MOSTAZAFEEN; f.k.a. “NATIONAL MOBILIZATION ORGANIZATION”; a.k.a. “NATIONAL RESISTANCE MOBILIZATION”; a.k.a. “RESISTANCE MOBILIZATION FORCE”), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IRGC] [IFSR] [IRAN-HR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE; Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). -to- BASIJ RESISTANCE FORCE (a.k.a. BASEEJ; a.k.a. BASIJ; a.k.a. BASIJ RESISTANCE FORCES; a.k.a. BASIJ-E MELLI; a.k.a. ISLAMIC REVOLUTION GUARDS CORPS RESISTANCE FORCE; a.k.a. MOBILIZATION OF THE OPPRESSED ORGANIZATION; a.k.a. NIROOYE MOGHAVEMATE BASIJ; a.k.a. NIRUYEH MOGHAVEMAT BASIJ; a.k.a. SAZEMAN-E BASIJ-E MOSTAZAFAN; f.k.a. SAZMAN BASIJ MELLI; a.k.a. SAZMAN-E MOGHAVEMAT-E BASIJ; a.k.a. VAHED-E BASIJ MOSTAZA’FEEN; f.k.a. VAHED-E BASIJ-E MOSTAZAFEEN; a.k.a. “MOBILIZATION OF THE OPPRESSED”; a.k.a. “MOBILIZATION OF THE OPPRESSED UNIT”; f.k.a. “NATIONAL MOBILIZATION ORGANIZATION”; a.k.a. “NATIONAL RESISTANCE MOBILIZATION”; a.k.a. “ORGANIZATION OF THE MOBILISATION OF THE OPPRESSED”; a.k.a. “RESISTANCE MOBILIZATION FORCE”), Tehran, Iran; Syria; Additional Sanctions Information – Subject to Secondary Sanctions [FTO] [SDGT] [IRGC] [IFSR] [IRAN-HR](Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE; Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS).

ISLAMIC REVOLUTIONARY GUARD CORPS (a.k.a. AGIR; a.k.a. IRANIAN REVOLUTIONARY GUARD CORPS; a.k.a. IRG; a.k.a. IRGC; a.k.a. ISLAMIC REVOLUTIONARY CORPS; a.k.a. PASDARAN; a.k.a. PASDARAN-E ENGHELAB-E ISLAMI; a.k.a. PASDARAN-E INQILAB; a.k.a. REVOLUTIONARY GUARD; a.k.a. REVOLUTIONARY GUARDS; a.k.a. SEPAH; a.k.a. SEPAH PASDARAN; a.k.a. SEPAH-E PASDARAN-E ENQELAB-E ESLAMI; a.k.a. THE ARMY OF THE GUARDIANS OF THE ISLAMIC REVOLUTION; a.k.a. THE IRANIAN REVOLUTIONARY GUARDS), Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [NPWMD] [IRGC] [IFSR] [IRAN-HR] [HRIT-IR]. -to- ISLAMIC REVOLUTIONARY GUARD CORPS (a.k.a. AGIR; a.k.a. ARMY OF THE GUARDIANS OF THE ISLAMIC REVOLUTION; a.k.a. IRAN’S REVOLUTIONARY GUARD CORPS; a.k.a. IRAN’S REVOLUTIONARY GUARDS; a.k.a. IRG; a.k.a. IRGC; a.k.a. ISLAMIC REVOLUTION GUARDS CORPS; a.k.a. ISLAMIC REVOLUTIONARY CORPS; a.k.a. ISLAMIC REVOLUTIONARY GUARDS; a.k.a. ISLAMIC REVOLUTIONARY GUARDS CORPS; a.k.a. PASDARAN; a.k.a. PASDARAN-E INQILAB; a.k.a. PASDARN-E ENGHELAB-E ISLAMI; a.k.a. REVOLUTIONARY GUARD; a.k.a. REVOLUTIONARY GUARDS; a.k.a. SEPAH; a.k.a. SEPAH PASDARAN; a.k.a. SEPAH-E PASDARAN ENGHELAB ISLAMI; a.k.a. SEPAH-E PASDARAN-E ENGHELAB-E ESLAMI; a.k.a. SEPAH-E PASDARAN-E ENQELAB-E ESLAMI; a.k.a. THE ARMY OF THE GUARDIANS OF THE ISLAMIC REVOLUTION; a.k.a. THE IRANIAN REVOLUTIONARY GUARDS), Tehran, Iran; Syria; Additional Sanctions Information – Subject to Secondary Sanctions; Additional Program Tags – [FTO] [SDGT] [NPWMD] [IRGC] [IFSR] [IRAN-HR] [HRIT-IR].

ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE (a.k.a. PASDARAN-E ENGHELAB-E ISLAMI (PASDARAN); a.k.a. SEPAH-E QODS (JERUSALEM FORCE)); Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [SYRIA] [IRGC] [IFSR] [IRAN-HR]. -to- ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE (a.k.a. AL QODS; a.k.a. IRGC-QF; a.k.a. IRGC-QUDS FORCE; a.k.a. ISLAMIC REVOLUTIONARY GUARD CORPS-QODS FORCE; a.k.a. JERUSALEM FORCE; a.k.a. PASDARAN-E ENGHELAB-E ISLAMI (PASDARAN); a.k.a. QODS (JERUSALEM) FORCE OF THE IRGC; a.k.a. QODS FORCE; a.k.a. QUDS FORCE; a.k.a. SEPAH-E QODS; a.k.a. SEPAH-E QODS (JERUSALEM FORCE)), Tehran, Iran; Syria; Additional Sanctions Information – Subject to Secondary Sanctions [FTO] [SDGT] [SYRIA] [IRGC] [IFSR] [IRAN-HR].

ISLAMIC REVOLUTIONARY GUARD CORPS AIR FORCE (a.k.a. IRGC AIR FORCE; a.k.a. SEPAH PASDARAN AIR FORCE), Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [NPWMD] [IRGC] [IFSR]. -to- ISLAMIC REVOLUTIONARY GUARD CORPS AIR FORCE (a.k.a. AEROSPACE DIVISION OF IRGC; a.k.a. AEROSPACE FORCE OF THE ARMY OF THE GUARDIANS OF THE ISLAMIC REVOLUTION; a.k.a. AFAGIR; a.k.a. AIR FORCE, IRGC (PASDARAN); a.k.a. IRGC AEROSPACE FORCE; a.k.a. IRGC AIR FORCE; a.k.a. IRGCAF; a.k.a. IRGCASF; a.k.a. ISLAMIC REVOLUTION GUARDS CORPS AIR FORCE; a.k.a. ISLAMIC REVOLUTIONARY GUARDS CORPS AEROSPACE FORCE; a.k.a. ISLAMIC REVOLUTIONARY GUARDS CORPS AIR FORCE; a.k.a. SEPAH PASDARAN AIR FORCE), Tehran, Iran; Syria; Additional Sanctions Information – Subject to Secondary Sanctions [FTO] [SDGT] [NPWMD] [IRGC] [IFSR].

And Treasury issued the following press release on the individuals being designated:

Treasury Designates Key Nodes of ISIS’s Financial Network Stretching Across the Middle East, Europe, and East Africa

Action Targets ISIS Financial Facilitators and Money Transfer Company

Washington – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated seven individuals and one entity pursuant to Executive Order (E.O.) 13224, which targets terrorists and those providing support to terrorists or acts of terrorism.  Specifically, OFAC designated key financial facilitators and conduits for the Islamic State of Iraq and Syria (ISIS) operating in Europe, Africa, and the Middle East.  Six individuals, located in Iraq, Turkey, and Belgium, and the entity, an Iraq, Turkey, and Syria-based money services business (MSB), are part of the Rawi Network, a key ISIS financial facilitation group based out of Iraq, which was the target of a joint Treasury-Department of Defense (DOD) action in October 2018.  In that action, OFAC designated Iraq-based MSB Afaq Dubai, and the Combined Joint Task Force-Operation Inherent Resolve (CJTF-OIR) released details regarding its support to a joint Iraqi Special Operations Forces and Kurdish Counter Terrorism Forces action against members of the Rawi Network who leveraged Afaq Dubai to facilitate the movement of funds for ISIS.  The seventh individual designated today is a Kenya-based female financial facilitator who has played an important role in an ISIS facilitation network in East Africa.

These designations coincide with the eleventh meeting of the Counter-ISIS Finance Group (CIFG), which includes 54 countries and international partners.  As a working group of the Global Coalition to Defeat ISIS, the CIFG plays a fundamental role in coordinating efforts to isolate ISIS from the international financial system and eliminate its sources of revenue.

“This action is directed at the Iraqi-based Rawi Network, which has used hawalas and money service businesses to circumvent the formal banking sector and move terror funds for ISIS across Europe, Africa and the Middle East.  Treasury is dedicated to ensuring the enduring defeat of ISIS by cutting off all remaining sources of their terror funding around the globe,” said Sigal Mandelker, Under Secretary for Terrorism and Financial Intelligence. “Our sanctions underscore how the ISIS threat has morphed, with financial cells on multiple continents, and with female operatives such as Halima Adan Ali, a Kenya-based financial facilitator.”

In order to capitalize fully on this important action, the United States Government worked closely and shared actionable information with the Government of Iraq (GOI), which continues to be a key partner in the fight against ISIS. 

As a result of today’s action, all property and interests in property of these persons, and of any entities that are owned, directly or indirectly, 50 percent or more by the designated persons, 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.

Background on the Rawi Network

Seasoned Money Launderers

Senior members of the Rawi Network got their start in the money services business to help the regime of Saddam Hussein evade sanctions during the early 1990s.  The Saddam Regime used Iraqi MSBs, including those owned by the Rawi Network, to avoid using the formal banking sector to buy and sell oil.  Since then, the Rawi Network has transitioned to supporting ISIS financial facilitation worldwide by employing common money laundering techniques such as cutouts, layering, and cash smuggling to obfuscate the source of illicit ISIS money.  For example, on a regular basis, the Deputy Commander for ISIS Department of Oil transferred between $300,000 to $400,000 to Umar Talib Zughayr al-Rawi—one of the individuals designated today—to buy and sell gold and eventually revert the gold proceeds back into cash for ISIS.

Successors of ISIS Finance Emir Fawaz al-Rawi

Two of the individuals designated today, Umar Talib Zughayr al-Rawi and Abd al Rahman ‘Ali Husayn al-Ahmad al-Rawi, were selected to manage the financial affairs for ISIS’s so-called province, or Wilayah, of al-Furat after the death in a Coalition airstrike in 2017 of Treasury-designated Fawaz Muhammad Jubayr al-Rawi (Fawaz), who was a Syrian terrorist financial facilitator who moved millions of dollars for ISIS’s attack and logistics networks.  Umar, Abd al-Rahman, and Mushtaq Talib Zughayr al-Rawi (another individual designated today) were all business partners with Fawaz.  An exploitation of financial records associated with Mushtaq revealed a history of direct money transfers to support ISIS provincial leaders through Al-Ard Al-Jadidah Money Exchange Company, the MSB designated today.

 

 

financial ledger

 

Figure 1: In 2018, Coalition Partner Forces obtained financial ledgers in an ISIS cache.  A forensic DNA sample obtained from a ledger book captured by Coalition and Partner Forces in 2018 linked Mushtaq to the cache containing this document.  Coalition Forces had previously detained Mushtaq in 2007 in al-Qa’im, Iraq as a suspected insurgent financier.  This letter contains an official ISIS seal along with an undated handwritten note signed by the “The Office of the Wali, The Islamic State, Caliphate on the Path of the Prophet, Wilayah of al-Furat” requesting that Mushtaq assist another individual to initiate a money transfer.

 

Exploitation of Iraq Government Payment Systems

Members of the Rawi Network registered several businesses with the GOI in order to acquire QiCard machines, a dedicated system of electronic payment machines used by the GOI to disburse payments to government employees and retirees.  They used these machines to launder funds for ISIS inside and outside of Iraq.  The Rawi Network used funds provided by ISIS to purchase and license at least five QiCard machines.

Designated Persons:

Mushtaq Talib Zughayr al-Rawi

Mushtaq Talib Zughayr al-Rawi (Mushtaq) was designated for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, ISIS.

Mushtaq is a leader of the Rawi Network.  Mushtaq assumed the leadership role of the Rawi Network for Turkey and Iraq in 2018 from another family member.  Mushtaq operates the Rawi Network with the assistance of various family members, including his son, Muhannad Mushtaq Talib Zughayr al-Rawi, his brothers, Umar Talib Zughayr al-Rawi and Walid Talib Zughayr al-Rawi, and other family members, including Abd-al-Rahman al-Rawi.  As of December 2018, Mushtaq was living in Belgium with his family, and he laundered money to facilitate ISIS operations worldwide.  He owns money exchange shops in Iraq, Syria, Turkey, Sudan, and the Gulf.  

In late November 2018, Coalition Forces advisors and their Partner Force conducted a direct action raid of a compound owned by Mushtaq and seized financial records revealing evidence of his business dealings with ISIS.  This included a page containing the ISIS seal, along with a handwritten note requesting that Mushtaq assist another individual initiate a money transfer.  The note is signed “The Office of the Wali” from “The Islamic State, Caliphate on the Path of the Prophet, Wilayah of al-Furat.”  See Figure 1.

As of October 2018, Belgium-based Mushtaq operated a finance network that allegedly used various commercial establishments in Iraq, hawalas in Iraq and Turkey, unidentified individuals in the Gulf, and an unidentified West Bank-based charity to generate, launder, and move cash into Iraq and Syria on behalf of ISIS.

As of early May 2018, Mushtaq and a family member operated an ISIS hawala from Al­Ard Al-Jadidah Money Exchange Company in Samsun, Turkey. Mushtaq’s family member operated the business while Mushtaq traveled to Belgium.  They also used the GOI pension system to launder funds for ISIS, and Mushtaq owns at least three QiCard businesses in al-Qa’im and Ramadi, Iraq and Samsun, Turkey.  As of November 2017, Mushtaq oversaw money transfers for ISIS using a hawala network throughout Iraq and Turkey.

ISIS members in Idlib Province, Syria were paid by a finance administrator who sent the payroll to a MSB owned by Mushtaq and another individual in Dayr az Zawr Province, Syria.

Additionally, Coalition Forces previously detained Mushtaq in 2007, in al-Qa’im, Iraq as a suspected insurgent financier.  Mushtaq is a former Captain in Saddam Hussein’s Republican Guards.

 

Umar Talib Zughayr al-Rawi

Umar Talib Zughayr al-Rawi (Umar) was designated for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to, or in support of, ISIS.

As of early October 2017, Umar owned several companies in Iraq, Syria, and Turkey and was in charge of performing transactions for ISIS in those countries.  Umar’s main hawala was located in the vicinity of al-Qa’im, Anbar Province, Iraq.

As of late 2017, ISIS financial facilitator Abd-al-Rahman al-Rawi, also designated today, and his business partner and cousin, Umar, had been selected to manage financial affairs for ISIS’s so-called Wilayah al-Furat following the death of Fawaz al-Rawi.  Abd-al-Rahman and Umar had been partners in a currency exchange company in al-Qa’im, Anbar Province, Iraq with Fawaz al-Rawi.  Both Abd-al-Rahman and Umar had formally accepted their appointments. Umar was responsible for money transfers inside Iraq.  In addition to dealing with large sums of money arriving from abroad and distributing the funds to ISIS’s Iraqi and Syrian provinces, Umar and Abd-al-Rahman also distributed Iraqi retirees’ salaries from the GOI via an electronic payment system.  Umar and Abd-al-Rahman also transferred funds to Iraq to purchase vehicles for ISIS fighters and exchanged cash for ISIS coinage.

As of early September 2017, Umar was an ISIS financial facilitation leader who received both money and gold from ISIS and transferred the money (or equivalent value of the gold) for ISIS.  He transferred money throughout Iraq, and conducted transactions to and from Turkey.

He operated businesses in al-Qa’im, Ramadi, Hit, and Baghdad, Iraq; Albu Kamal, Syria; and Turkey.  In al-Qa’im, Umar operated an exchange house, handling large amounts of money, and transferred money for ISIS.  In Ramadi, Iraq, Umar was the co-owner of an exchange house that ISIS used to make a significant number of money transfers within Anbar Province, Iraq.  Umar had other hawalah and money transfer offices used by ISIS members, which were operated in partnership with other Rawi Network members.

 

Walid Talib Zughayr al-Rawi

Walid Talib Zughayr al-Rawi (Walid) was designated for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to, or in support of, Mushtaq.

Mushtaq moved money for ISIS out of al-Qa’im, Iraq and Samsun, Turkey.  However, Mushtaq’s brother, Walid, was purportedly the brains behind the finance operation.  On October 9, 2018 the Iraq Counterterrorism Service (CTS) conducted a warrant-based arrest of Walid to disrupt the ISIS financial network. 

Mushtaq and Walid started in the money exchange business when sanctions were placed on Iraq’s oil exports in the 1990s.

Walid has held money from numerous relatives and associates.  These individuals were investing in Walid’s various enterprises, to include Walid’s numerous GOI contracts.  These individuals were given a certain rate of return or interest on their investment.  Mushtaq invested $900,000 with Walid.  Moreover, Mushtaq had Walid transfer money to two gold shops in the Gulf.  Walid transferred these funds approximately three times per month, totaling $100,000, and started sending money to these gold shops for approximately one year prior to Walid’s detention on October 9, 2018.

Walid informed an unidentified individual of nearly $3.9 million in financial transactions for funds sent to entities in Iraq and the Gulf from early December 2017 through early July 2018.  The unidentified individual noted that at least $700,000 was deposited for Mushtaq as of February 2018.

Walid maintained accounts and records for Mushtaq,

Walid was also designated for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to, or in support of, Umar.

Walid handled transfers to and from a Gulf-based exchange on behalf of Umar as well as Umar’s investments in unspecified businesses. Umar has $500,000 invested with Walid.

 

Muhannad Mushtaq Talib Zughayr al-Rawi

Muhannad Mushtaq Talib Zughayr al-Rawi (Muhannad) was designated for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to, or in support of, Mushtaq.

Mushtaq’s financial activity consisted of a cycle of monetary transactions that included his son Muhannad and three other financial facilitators.  When Mushtaq conducted transactions with a certain exchange company, he moved money from Turkey to Muhannad.  Muhannad then moved Mushtaq’s money to the exchange, which then transferred Mushtaq’s money to a gold exchange in the Gulf, earmarked for a specific gold seller.

As of September 2017, Muhannad moved from Baghdad, Iraq to Samsun, Turkey, to work with Mushtaq.

 

Abd-al-Rahman ‘Ali Husayn al-Ahmad al-Rawi

Abd-al-Rahman ‘Ali Husayn al-Ahmad al-Rawi (Abd-al-Rahman) was designated for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to, or in support of, ISIS.

As of September 2018, both Istanbul, Turkey-based Syrian national Abd-al­Rahman and an Idlib Province, Syria-based Syrian hawaladar had allegedly established a secret partnership with two Syria-based Iraqi brothers to facilitate financial transfers into Syria on behalf of ISIS via hawala networks.  Both the Syria-based hawaladar and Abd-al-Rahman conducted a large volume of legitimate business through their companies. However, they also moved money for ISIS in secret.

As of late 2017, a Turkey-based merchant, who was one of the primary ISIS financial facilitators in Syria, maintained a business partnership with ISIS financier Abd-al-Rahman.  Abd-al-Rahman was one of a few individuals who provided ISIS significant financial facilitation into and out of Syria.  Abd-al-Rahman instructed ISIS fighters seeking to move large sums of money out of Syria to deposit the money with an office in Syria.  Furthermore, when individuals wanted to send money from Turkey to ISIS members in Syria, the instructions involved Abd-al­Rahman’s.

Abd-al-Rahman had a hard-currency liquidity of several million dollars in Syria.  He served as ISIS’s general financial manager, and prior to his relocation to Turkey, he traveled around Syria on behalf of the group.  As of late October 2017, Abd-al-Rahman allegedly continued conducting financial transactions on behalf of ISIS.  As of mid-November 2017, Abd-al­Rahman maintained a close and continuing partnership with an unidentified merchant, moving large sums of money on behalf of ISIS.  Abd-al-Rahman was so influential within ISIS that he had the capacity to reduce a death sentence into a short prison term.

As of late 2017, Abd-al-Rahman and his business partner and cousin, Umar, also designated today, had been selected to manage financial affairs for ISIS’s Wilayah al-Furat following the death of Fawaz al-Rawi.  As of late 2017, both Abd-al-Rahman and Umar, who had been partners in a currency exchange company in al-Qa’im, Anbar Province, Iraq, with Fawaz al-Rawi, had formally accepted their appointments.  Abd-al-Rahman was responsible for external ISIS money transfer originating from and destined to foreign countries.

Abd-al-Rahman entered into a secret business relationship with a Turkey-based individual who specialized in conducting large-sum hawala transfers from the Gulf, including funds intended for ISIS.   This individual facilitated a $250,000 hawala transfer to Abd-al-Rahman.

 

Muhammad Abd-al-Qadir Mutni Assaf al-Rawi

Muhammad Abd-al-Qadir Mutni Assaf al-Rawi (Muhammad) was designated for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to, or in support of, ISIS.

Muhammad was used to transfer Mushtaq’s money to two gold shops in the Gulf, and Muhammad transferred approximately $100,000 per month for these transactions.

As of February 2017, ISIS financial facilitator in Iraq, Walid al-Rawi, also designated today, used Muhammad to conduct a financial transfer of U.S. $40,000 to a Turkey-based ISIS financial facilitator.

As of 2016, ISIS members used Muhammad and his business to transfer money to various countries in the Middle East and Europe.

                                         

Al-Ard Al-Jadidah Money Exchange Company

Al-Ard Al-Jadidah Money Exchange Company (Al-Ard Al-Jadidah ) was designated for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to, or in support of, ISIS.

As of late 2018, Al-Ard al-Jadidah served as a money exchange used by ISIS members in Iraq and was wittingly transferring money for ISIS and delivering money to all the provinces of lraq.  In 2018, an ISIS member collected a hawala transfer of over one million dollars on behalf of ISIS at a branch of Al-Ard al-Jadidah in Iraq.  Separately, in 2018, an ISIS member collected a transfer of hundreds of thousands of dollars from Al-Ard al-Jadidah in Ramadi, Anbar Province, Iraq.  These funds were designated as financial support intended for distribution to ISIS family members.

Additionally, in late October 2018, Mushtaq facilitated money transfers between Al-Ard al-Jadidah in Samsun, Turkey and hawalas in Iraq.

 

Halima Adan Ali

Halima Adan Ali (Halima) was designated for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to, or in support of, ISIS.

Halima played an integral role in an ISIS financial facilitation network spanning Europe, the Middle East, the Americas and Eastern Africa.  She worked with Treasury-designated Waleed Ahmaed Zein to conduct transactions at the behest of Waleed’s Syria-based family member in support of ISIS fighters.  Between 2017 and early 2018, Halima received large sums of money from around the world, mostly through hawala systems, that she would forward to ISIS fighters in Syria, Libya, and central Africa.  She was also used as a conduit to pass instructions, money, and accounts to Waleed. Their intricate network moved over $150,000 on behalf of ISIS.

Halima, who before becoming associated with ISIS served as an extremist recruiter and facilitator for al-Shabaab, planned to travel from East Africa to Syria and other ISIS supported areas in August 2014, but was left behind when she was arrested for activities in support of al-Shabaab.  Waleed’s Syria-based family member worked through proxy channels to provide funds to secure Halima’s release from prison on bond, after which she began to work closely with him in support of ISIS.  Halima was arrested again by Kenyan security services in July 2018.

Links:

OFAC Notice

Treasury Press Release

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SECO removes DHDS from terror sanctions

April 16, 2019, 6:35 am
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Earlier today, Swiss authorities removed:

SSID: 10-17431 Foreign identifier: QE.D.102.03. Name: Djamat Houmat Daawa Salafia (DHDS)

Good quality a.k.a.: Djamaat Houmah Al-Dawah Al-Salafiat F.k.a.: Katibat el Ahouel Address: Algeria

Relation: a) Associated with Armed Islamic Group (QE.A.6.01., SSID 10-17382) b) Associated with The Organization of Al-Qaida in the Islamic Maghreb (QE.T.14.01., SSID 10-17785) Other information: Associated with the Armed Islamic Group (GIA) (QE.A.6.01) and the Organization of Al-Qaida in the Islamic Maghreb (QE.T.14.01). Review pursuant to Security Council resolution 1822 (2008) was concluded on 30 Jul 2009. Modifications: De- listed on 13 Apr 2019

from their Al-Qaida/bin Laden/Taliban counter terrorism sanctions program.

Links:

FINMA Notice

Data files of updates – PDF, XML

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April 15, 2019: EU, OFSI remove more Iraqi entities

April 16, 2019, 6:45 am
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On Monday, UK regulators implemented Commission Implementing Regulation (EU) 2019/596 by removing:

1. AL HASSAKA SPINNING PROJECT

Address: PO Box 46, Al Hassaka Al Azizeh, Iraq.Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 15/04/2019 Group ID: 8055.

2. DIWANIYA STATE COTTON TEXTILE COMPANY

a.k.a: Diwaniya Cotton State Company Address: (1) PO Box 15, Diwaniyah, Iraq.(2) PO Box 79, Diwaniya, Qadisiya, Iraq.Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 15/04/2019 Group ID: 8080.

3. FINE TEXTILE STATE COMPANY

Address: PO Box 2, Hilla, Iraq.Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 15/04/2019 Group ID: 8083.

4. GENERAL ESTABLISHMENT FOR WOOLLEN TEXTILE

a.k.a: Woollen Textile State Company Address: PO Box 9114, Khadhumiya, Baghdad, Iraq.Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 15/04/2019 Group ID: 8102.

5. IRAQI TEXTILE STATE ESTABLISHMENT

a.k.a: Iraqi State Textile Company Address: Al Nawab Street, Khadhumiya, PO Box 9106, Baghdad, Iraq.Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 15/04/2019 Group ID: 8121.

6. KUT COTTON TEXTILE STATE COMPANY

a.k.a: (1) Kut Industrial Company (2) Training Centre For Textile Industries/Kut Address: (1) Kut Opp, Al-Zahra Town, Iraq.(2) PO Box 25, Kut, Iraq.(3) PO Box 5613, South Gate, Kut, Iraq.Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 15/04/2019 Group ID: 8124.

7. MOSUL STATE COMPANY FOR TEXTILE

Address: PO Box 18, Mosul, Iraq.Listed on: 05/05/2004 Last Updated: 05/05/2004

15/04/2019 Group ID: 8359.

8. NATIONAL STATE COMPANY FOR TEXTILE

Address: PO Box 5664, Kadhumia, Baghdad, Iraq.Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 15/04/2019 Group ID: 8145.

9. STATE ENTERPRISE FOR HANDWOVEN CARPETS

a.k.a: Handwoven Carpets State Company Address: Al Nasir Square, Arbil, Iraq.Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 15/04/2019 Group ID: 8104.

10. STATE ENTERPRISE FOR LEATHER INDUSTRIES

a.k.a: State Leather Industries Company Address: Karrada Al Sharkiya, Hurriya Square, PO Box 3079, Baghdad, Iraq.Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 15/04/2019 Group ID: 8185.

11. STATE SEWING COMPANY

Address: PO Box 14007, Waziriya, Baghdad, Iraq.Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 15/04/2019 Group ID: 8231.

12. WOOLLEN INDUSTRIES FACTORY OF ARBIL

a.k.a: Woollen Textile State Company In Arbil Address: PO Box 101, Arbil, Iraq.Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 15/04/2019 Group ID: 8242.

13. WOOLLEN TEXTILE STATE EST IN NASSIRIYAH

a.k.a: Woollen Textile State Company In Nasirya Address: PO Box 108, Nassiriyah, Iraq.Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 15/04/2019 Group ID: 8243.

from their Iraq sanctions program.

Links:

OFSI Notice

Commission Implementing Regulation (EU) 2019/596

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April 15, 2019: UN, OSFI remove 1 from counter terror list

April 16, 2019, 7:20 am
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On Monday, Canadian officials removed:

QDe.102 Name: DJAMAT HOUMAT DAAWA SALAFIA (DHDS)
Name (original script): جماعة حماة الدعوة السلفية
A.k.a.: Djamaat Houmah Al-Dawah Al-Salafiat F.k.a.: Katibat el AhouelAddress: Algeria Listed on: 11 Nov. 2003 (amended on 26 Nov. 2004, 7 Apr. 2008, 25 Jan. 2010, 13 Dec. 2011) Other information: Associated with the Armed Islamic Group (GIA) (QDe.006) and the Organization of Al-Qaida in the Islamic Maghreb (QDe.014).  Review pursuant to Security Council resolution 1822 (2008) was concluded on 30 Jul. 2009.  INTERPOL-UN Security Council Special Notice web link: www.interpol.int/en/notice/search/une/5278400.

from their counter terror sanctions, after his removal by the United Nations ISIL (Da’esh) and Al-Qaida Sanctions Committee.

Links:

OSFI Notice

UN Notice

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While I was at ACAMS: 3-for-1 OFAC settlements with UniCredit Germany, Austria and Italy units

April 16, 2019, 8:00 am
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Settlement Agreements between the U.S. Department of the Treasury’s Office of Foreign Assets Control and UniCredit Group Banks

4/15/2019

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced three separate settlements totaling $611 million with the following UniCredit Group banks: UniCredit Bank AG in Germany, UniCredit Bank Austria AG in Austria, and UniCredit S.p.A. in Italy.  The settlements resolve OFAC’s investigations into apparent violations of a number of U.S. sanctions programs, including those related to weapons of mass destruction proliferation, global terrorism, and the following countries: Burma, Cuba, Iran, Libya, Sudan, and Syria.

Between January 2007 and December 2011, UniCredit Bank AG processed over 2,000 payments totaling over $500 million through financial institutions in the United States in apparent violation of multiple U.S. sanctions programs.  During this time period, UniCredit operated U.S. dollar accounts on behalf of the Islamic Republic of Iran Shipping Lines (IRISL) and several companies owned by or otherwise affiliated with IRISL, and managed the accounts of those companies in a manner that obscured the interest or involvement of IRISL in transactions sent to or through U.S. intermediaries.  For a number of years up to and including 2011 (UniCredit Bank AG) and 2012 (UniCredit Bank Austria AG and UniCredit S.p.A.), all three banks processed payments to or through the United States in a manner that did not disclose underlying sanctioned persons or countries to U.S. financial institutions which were acting as financial intermediaries.

 

OFAC determined that the apparent violations largely constituted egregious cases and that the banks did not voluntarily self-disclose the apparent violations.

After Mr. Watchlist gets back from ACAMS, he will dig into the Enforcement Information and Settlement Agreements.

By the way, this is part of a multi-agency settlement totaling 1.3 billion dollars.

Links:

OFAC Notice

Enforcement Information

Settlement Agreements: UniCredit Bank AG (Germany), UniCredit Bank Austria AG, UniCredit S.p.A. (Italy)

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HKMA Alert: Fraudulent DBS Bank website

April 17, 2019, 6:05 am
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Press Releases

Fraudulent website related to DBS Bank (Hong Kong) Limited

The Hong Kong Monetary Authority (HKMA) wishes to alert members of the public to a press release issued by DBS Bank (Hong Kong) Limited on fraudulent website, 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 website concerned or has conducted any financial transactions through the website 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
12 March 2019

Link:

HKMA Notice

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March 29, 2019: HK SFC AML/CFT Circular

April 18, 2019, 6:30 am
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Circular to Licensed Corporations and Associated Entities 
Anti-Money Laundering / Counter-Financing of Terrorism
(1) United Nations Sanctions (Libya) Regulation 2019 and United Nations Sanctions (Libya) Regulation 2011 (Repeal) Regulation 
(2) United Nations Sanctions (Somalia) Regulation 2019 and United Nations Sanctions (Somalia) Regulation (Repeal) Regulation 
(3) United Nations Sanctions (Eritrea) Regulation (Repeal) Regulation

29 Mar 2019

(1)  United Nations Sanctions (Libya) Regulation 2019 and United Nations Sanctions (Libya) Regulation 2011 (Repeal) Regulation

The United Nations Sanctions (Libya) Regulation 2019 (“the Libya Regulation 2019”) and the United Nations Sanctions (Libya) Regulation 2011 (Repeal) Regulation (“the Libya Repeal Regulation”), made under the United Nations Sanctions Ordinance (Cap. 537) (“UNSO”), were published in the Gazette (L.N. 53 & 54 of 2019) on 29 March 2019 with immediate effect.

The Libya Regulation 2019 implements all sanctions and exemptions imposed by the United Nations Security Council (“UNSC”) on Libya, including those extended by UNSC Resolution 2441, using modernised provisions to improve tidiness and readability of the legislation. Consequential to the making of the Libya Regulation 2019, the Libya Repeal Regulation repeals the United Nations Sanctions (Libya) Regulation 2011 Note 1.

We would like to draw licensed corporations’ (“LCs”) and associated entities’ (“AEs”) attention to section 9 of the Libya Regulation 2019 which provides for prohibition against making available economic assets to certain persons or entities, or dealing with economic assets of such persons or entities, except with a licence.

The Libya Regulation 2019 and the Libya Repeal Regulation can be found on the Government’s website (https://www.gld.gov.hk/egazette/pdf/20192313/es22019231353.pdf & https://www.gld.gov.hk/egazette/pdf/20192313/es22019231354.pdf) respectively.

A list specifying “relevant persons and entities” was published under section 43 of the Libya Regulation 2019 on the website of the Commerce and Economic Development Bureau on 29 March 2019.

The aforesaid list obtained from the website of the Commerce and Economic Development Bureau is attached in Attachment 1.

(2)  United Nations Sanctions (Somalia) Regulation 2019 and United Nations Sanctions (Somalia) Regulation (Repeal) Regulation

The United Nations Sanctions (Somalia) Regulation 2019 (“the Somalia Regulation 2019”) and the United Nations Sanctions (Somalia) Regulation (Repeal) Regulation (“the Somalia Repeal Regulation”) made under the UNSO was published in the Gazette (L.N. 55 & 56 of 2019) on 29 March 2019 with immediate effect.

The Somalia Regulation 2019 implements all sanctions and exemptions imposed by the UNSC on Somalia, including those extended by UNSC Resolution 2444, using modernised provisions to improve tidiness and readability of the legislation. Consequential to the making of the Somalia Regulation 2019, the Somalia Repeal Regulation repeals the United Nations Sanctions (Somalia) Regulation Note 2.

We would like to draw LCs’ and AEs’ attention to section 6 of the Somalia Regulation 2019 which provides for prohibition against making available economic assets to certain persons or entities, or dealing with economic assets of such persons or entities, except with a licence.

The Somalia Regulation 2019 and the Somalia Repeal Regulation can be found on the Government’s website (https://www.gld.gov.hk/egazette/pdf/20192313/es22019231355.pdf & https://www.gld.gov.hk/egazette/pdf/20192313/es22019231356.pdf) respectively.

A list specifying “relevant persons and entities” was published under section 29 of the Somalia Regulation 2019 on the website of the Commerce and Economic Development Bureau on 29 March 2019.

The aforesaid list obtained from the website of the Commerce and Economic Development Bureau is attached in Attachment 2.

(3)  United Nations Sanctions (Eritrea) Regulation (Repeal) Regulation

The United Nations Sanctions (Eritrea) Regulation (Repeal) Regulation (“the Eritrea Repeal Regulation”) made under the UNSO was published in the Gazette (L.N. 57 of 2019) on 29 March 2019 with immediate effect.

The Eritrea Repeal Regulation repeals the United Nations Sanctions (Eritrea) Regulation Note 3 to implement the UNSC’s decision to lift the sanctions previously imposed on Eritrea.

The Eritrea Repeal Regulation can be found on the Government’s website (https://www.gld.gov.hk/egazette/pdf/20192313/es22019231357.pdf).

LCs and AEs are reminded to refer to Chapter 6 of the Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Licensed Corporations) (“AML Guideline”) which contains guidance on the appropriate measures that LCs and AEs should take to ensure compliance with the regulations made under the UNSO Note 4. The Securities and Futures Commission expects all new designations to be screened by LCs and AEs against their client lists as soon as practicable whenever there are updates. LCs and AEs are also reminded to report any transactions or relationships they have or have had with any designated person or entity to the Joint Financial Intelligence Unit.

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

Enclosure

End

SFO/IS/014/2019

Note 1 Please refer to our circular issued on 29 September 2017 for information on the United Nations Sanctions (Libya) Regulation 2011 (https://www.sfc.hk/edistributionWeb/gateway/EN/circular/aml/aml-sanction-related/doc?refNo=17EC65).

Note 2 Please refer to our circular issued on 20 April 2018 for information on the United Nations Sanctions (Somalia) Regulation (https://www.sfc.hk/edistributionWeb/gateway/EN/circular/aml/aml-sanction-related/doc?refNo=18EC27).

Note 3 Please refer to our circular issued on 22 October 2010 for information on the United Nations Sanctions (Eritrea) Regulation (https://www.sfc.hk/edistributionWeb/gateway/EN/circular/aml/aml-sanction-related/openFile?refNo=H605).

Note 4 Under paragraph 6 of the Prevention of Money Laundering and Terrorist Financing Guideline issued by the Securities and Futures Commission for Associated Entities, AEs that are not authorized financial institutions are expected to have regard to the provisions of the AML Guideline as if they were themselves LCs.

Links:

HK SFC Notice

HK SFC Circular

Commerce and Economic Development Bureau List (Libya) – Attachment 1

Commerce and Economic Development Bureau List (Somalia) – Attachment 2

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April 1, 2019: HK SFC AML/CFT Circular

April 19, 2019, 6:30 am
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Circular to Licensed Corporations and Associated Entities

Anti-Money Laundering / Counter-Financing of Terrorism

(1)  United Nations (Anti-Terrorism Measures) Ordinance

(2)  United Nations Sanctions (ISIL and Al-Qaida) Regulation

(1)  United Nations (Anti-Terrorism Measures) Ordinance 

Further to our circular issued on 25 March 2019, an updated list specifying terrorists and terrorist associates designated by the United Nations Security Council (“UNSC”) was published under section 4 of the United Nations (Anti-Terrorism Measures) Ordinance (“the UNATMO”) (Cap. 575) in the Gazette (G.N. (E.) 17 of 2019) on 1 April 2019.  A relevant press release issued by the UNSC, reflecting the updates since the previous list was published in the Gazette (G.N. (E.) 13 of 2019), is attached in Attachment 1 Note 1.

The aforesaid list can be found on the Government’s website (https://www.gld.gov.hk/egazette/pdf/20192317e/egn2019231717.pdf).

(2)  United Nations Sanctions (ISIL and Al-Qaida) Regulation 

Further to our circular issued on 25 March 2019, an updated list specifying “individuals, groups, undertakings and entities” was published under section 25 of the United Nations Sanctions (ISIL and Al-Qaida) Regulation (Cap. 537CB) on the website of the Commerce and Economic Development Bureau on 30 March 2019. A relevant press release issued by the UNSC, reflecting the updates since the previous list was published on the website of the Commerce and Economic Development Bureau, is attached in Attachment 1 Note 1.

The aforesaid list obtained from the website of the Commerce and Economic Development Bureau is attached in Attachment 2.

Licensed corporations (“LCs”) and associated entities (“AEs”) are reminded to refer to Chapter 6 of the Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Licensed Corporations) (“AML Guideline”) which contains guidance on the appropriate measures that LCs and AEs should take to ensure compliance with the regulations made under the UNATMO (Cap. 575) and the United Nations Sanctions Ordinance (Cap.537) Note 2.  The Securities and Futures Commission expects all new designations to be screened by LCs and AEs against their client lists as soon as practicable whenever there are updates.  LCs and AEs are also reminded to report any transactions or relationships they have or have had with any designated person or entity to the Joint Financial Intelligence Unit.

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

Enclosure

End

SFO/IS/015/2019

Note 1 The updates made to the sanctions lists published under the UNATMO and the United Nations Sanctions (ISIL and Al-Qaida) Regulation are identical.
Note 2 Under paragraph 6 of the Prevention of Money Laundering and Terrorist Financing Guideline issued by the Securities and Futures Commission for Associated Entities, AEs that are not authorized financial institutions are expected to have regard to the provisions of the AML Guideline as if they were themselves LCs.

Links:

HK SFC Notice

HK SFC Circular

UN Press Releases (Attachment 1)

Commerce and Economic Development Bureau List (Attachment 2)

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On the last day at ACAMS: Venezuela and Nicaragua Sanctions updates

April 22, 2019, 6:05 am
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Last Wednesday, OFAC designated the following person:

RUZZA TERAN, Iliana Josefa (Latin: RUZZA TERÁN, Iliana Josefa), Caracas, Venezuela; DOB 27 Feb 1980; Gender Female; Cedula No. 14310920 (Venezuela) (individual) [VENEZUELA].

and entity:

BANCO CENTRAL DE VENEZUELA (a.k.a. CENTRAL BANK OF VENEZUELA), Av. Urdaneta, Esquina Las Carmelitas, Edif. Banco Central, Caracas, Venezuela; Av. Urdaneta, Esquina de Carmelitas, Distrito Capital, Caracas 1010, Venezuela; SWIFT/BIC BCVEVECA; Tax ID No. G200001100 (Venezuela) [VENEZUELA-EO13850].

under its Venezuela sanctions program, and the following person:

ORTEGA MURILLO, Laureano Facundo (a.k.a. ORTEGA, Laureano); DOB 20 Nov 1982; POB Managua, Nicaragua; nationality Nicaragua; Gender Male; Passport A00000684 (Nicaragua) expires 26 Sep 2023; National ID No. 0012011820046M (individual) [NICARAGUA].

and entity:

BANCO CORPORATIVO SA (a.k.a. “BANCO NACIONAL”; a.k.a. “BANCO NATIONAL”; a.k.a. “BANCORP”; a.k.a. “NATIONAL BANK”), 2 Cuadras Aloeste y 3 Cuadras Alnorte, Managua, Nicaragua; SWIFT/BIC BOFPNIMA [NICARAGUA].

under its Nicaragua program.

OFAC also updated 5 existing General Licenses (old names: 3D, 4A, 9C, 15 & 16) and issued two new ones (19 & 20).

They also issued one new Frequently Asked Question (FAQ):

665. Will the designation of Banco Central de Venezuela, or the Central Bank of Venezuela, restrict the ability of U.S. persons to engage in or facilitate the provision of humanitarian assistance or non-commercial, personal remittances to Venezuela?

No.  OFAC is committed to ensuring that humanitarian assistance and non-commercial, personal remittances can flow to the people of Venezuela.  To that end, concurrent with the designation of Banco Central de Venezuela, OFAC has issued amendments to current Venezuela-related general licenses and issued a new general license to ensure that U.S. persons may continue to engage in and facilitate non-commercial, personal remittances and the provision of humanitarian assistance to the people of Venezuela.  

Regarding humanitarian transactions, OFAC has updated General License 4A “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” to include Banco Central de Venezuela in the authorization for transactions ordinarily incident and necessary to the exportation or reexportation of agricultural commodities, medicine, medical devices, components, or replacement parts for medical devices, to Venezuela, or to persons in third countries purchasing specifically for resale to Venezuela, provided that the exportation or reexportation is licensed or otherwise authorized by the Department of Commerce, or for items not subject to the Export Administration Regulations, is not listed under any multilateral export control regime.  Furthermore, OFAC maintains a specific licensing regime that can evaluate on a case-by-case basis the authorization of humanitarian activities not covered under general licenses. 

OFAC has also revised General License 16 “Authorizing Maintenance of U.S. Person Accounts and Noncommercial, Personal Remittances involving Certain Banks” to include Banco Central de Venezuela to authorize all transactions and activities ordinarily incident and necessary to processing noncommercial, personal remittances involving certain banks (including Banco Central de Venezuela) through 12:01 a.m. eastern daylight time, March 22, 2020, as long as the transactions are not otherwise prohibited by OFAC’s Venezuela sanctions program. 

In addition, OFAC is issuing General License 20 “Authorizing Official Activities of Certain International Organizations Involving Banco Central de Venezuela” to authorize international organizations such as the United Nations and its specialized agencies and the International Committee of the Red Cross, among others, to engage in transactions with Banco Central de Venezuela to the extent the transactions are subject to U.S. jurisdiction.  Sanctions do not prohibit U.S. persons from engaging in transactions involving Venezuela (such as exporting or re-exporting items to Venezuela), provided that the transactions do not involve sanctioned individuals or entities or certain prohibited activity.

If individuals, companies, or financial institutions have questions about engaging in or processing transactions related to non-commercial, personal remittances or the provision of humanitarian assistance to Venezuela, they can contact OFAC’s Sanctions Compliance and Evaluation Division at (800) 540-6322 or (202) 622-2490. [04-17-2019]

Treasury issued a press release about Venezuela:

Treasury Sanctions Central Bank of Venezuela and Director of the Central Bank of Venezuela

Washington – Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Banco Central de Venezuela, or the Central Bank of Venezuela, pursuant to E.O. 13850, as amended, for operating in the financial sector of the Venezuelan economy.  Additionally, OFAC designated Iliana Josefa Ruzza Terán (Ruzza), pursuant to E.O. 13692, as amended, who is determined to be a current or former official of the Government of Venezuela.

“Treasury is designating the Central Bank of Venezuela to prevent it from being used as a tool of the illegitimate Maduro regime, which continues to plunder Venezuelan assets and exploit government institutions to enrich corrupt insiders,” said Treasury Secretary Steven T. Mnuchin.  “The United States is committed to helping the Venezuelan people.  While this designation will inhibit most Central Bank activities undertaken by the illegitimate Maduro regime, the United States has taken steps to ensure that regular debit and credit card transactions can proceed and personal remittances and humanitarian assistance continue unabated and are able to reach those suffering under the Maduro regime’s repression.”

This action targets a key entity and individual in Venezuela’s financial sector, which the Maduro regime continues to exploit in order to stay in power, and illustrates the Trump Administration’s resolve to prevent the Maduro regime from gaining access to the U.S. financial system, including through Venezuela’s central bank.

Today, OFAC designated the following persons:

• Banco Central de Venezuela is the central bank of Venezuela, and is based in Caracas.  Multiple OFAC-designated individuals currently hold leadership positions with the Banco Central de Venezuela, including Simon Alejandro Zerpa Delgado and William Antonio Contreras, both of whom are Directors of the bank and were designated by OFAC pursuant to E.O. 13692 in 2017 and 2018, respectively.

• Iliana Josefa Ruzza Terán is a Director of Banco Central de Venezuela.  Additionally, Ruzza was appointed in July 2018 as a Director on the Board of Directors for the Venezuelan Department of Foreign Commerce, also known as CORPOVEX, and was appointed in May 2018 to be the Vice President of Finance of Petroleos de Venezuela, S.A., which was designated on January 28, 2019, pursuant to E.O. 13850.

Concurrent with this designation, OFAC has issued amendments to current Venezuela-related general licenses and issued new general licenses, which include authorizations to ensure that U.S. persons may continue to engage in and facilitate non-commercial, personal remittances and the provision of humanitarian assistance to the people of Venezuela. 

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,” FIN-2017-A003, “Advisory to Financial Institutions and Real Estate Firms and Professionals” and FIN-2018-A003, “Advisory on Human Rights Abuses Enabled by Corrupt Senior Foreign Political Figures and their Financial Facilitators.”

As a result of today’s action, all property and interests in property of this entity and individual, and any entity that is owned, directly or indirectly, 50 percent or more by the designated entity or individual, 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.

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 illegitimate Maduro regime, and combat corruption in Venezuela.

and Nicaragua:

Treasury Targets Finances of Nicaraguan President Daniel Ortega’s Regime

WASHINGTON – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Laureano Ortega Murillo, the son of Nicaraguan President Daniel Ortega and Vice President Rosario Murillo, as well as Nicaraguan bank Banco Corporativo SA (BanCorp).  Today’s action, taken pursuant to Executive Order (E.O.) 13851, targets corrupt financial operations and Ortega regime support networks.  The individual and entity designated today support a regime that, since April 2018, has cracked down on political opposition, leading to the death of 325 persons, the injury of more than 2,000, the imprisonment of hundreds of political and civil society actors, and over 42,000 Nicaraguans seeking refuge in Costa Rica.

“President Ortega, Vice President Murillo, and members of their inner circle continue to engage in blatant corruption, violence, and violations of basic human rights.  The corrupt Ortega regime has ignored the Nicaraguan people’s calls for reform, including the freeing of all political prisoners, and early transparent elections,” said Sigal Mandelker, Under Secretary of the Treasury for Terrorism and Financial Intelligence.  “Treasury is sanctioning Laureano Ortega Murillo and BanCorp for their roles in corruption and money laundering for the personal gain of the Ortega regime.  These actions send a message to all who continue to prop up the Ortega regime that there is a steep price to pay for abusing the Nicaraguan economy and its people.” 

As a result of today’s actions, all property and interests in property of these persons, and of any entities that are owned, directly or indirectly, 50 percent or more by these persons, 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.  Further details on these designations are included below.

Banco Corporativo SA

BanCorp is being designated for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, Vice President Rosario Murillo, a person whose property and interests in property are blocked pursuant to E.O. 13851, and for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, any transaction or series of transactions involving corruption by, on behalf of, or otherwise related to the Government of Nicaragua or a current official of the Government of Nicaragua.  Created as a subsidiary to the Venezuelan government-funded Alba de Nicaragua, S.A. (ALBANISA) in 2014, BanCorp is a bank used by the Ortega regime to launder and hide ALBANISA money.  BanCorp is also reportedly used by President Ortega’s ruling Sandinista National Liberation Front (FSLN) party to launder money.  Finally, as of 2018, BanCorp has been a haven for OFAC sanctioned persons, allowing designated individuals to continue enjoying banking privileges and their ill-gotten wealth. 

BanCorp, as a subsidiary of ALBANISA, is ultimately owned by PETROLEOS DE VENEZUELA, S.A. (PdVSA) and, as such, was blocked by operation of law following the January 28, 2019, designation of PdVSA pursuant to E.O. 13850. 

Laureano Ortega Murillo

Laureano Ortega Murillo (Laureano) is being designated for being a current official of the Government of Nicaragua.  In his role as the Investment Promotion Advisor of the Nicaraguan government agency, ProNicaragua, Laureano acts as an extension of President Ortega and Vice President Murillo, overseeing investment proposals and projects.  However, as of 2018, Laureano engaged in corrupt business deals in which foreign investors paid for preferential access to the Nicaraguan economy.  Additionally, Laureano coordinated executive tasks for the Nicaragua Grand Canal project, and was at the center of its creation.  Despite the project’s loss of momentum, Ortega regime figures, including Laureano, continue to use the Nicaragua Grand Canal Company as a means to launder money and to acquire property along the planned canal route. 

And State, not to be outdone, issued two also – one for Venezuela:

The United States Sanctions the Central Bank of Venezuela

Media Note

Office of the Spokesperson

Washington, DC

April 17, 2019

Today, the United States has taken further action to halt the former Maduro regime’s theft of Venezuela’s assets and destruction of the economy.

The United States has sanctioned the Central Bank of Venezuela (BCV) for operating in the financial sector of the Venezuelan economy, pursuant to Executive Order 13850. Additionally, Iliana Josefa Ruzza Teran, a director of BCV, has been designated pursuant to Executive Order 13692.

As the central bank of Venezuela, the BCV formulates and implements Venezuela’s monetary policy, issues currency, and manages the country’s international reserves. The regime’s failed policies have turned a once prosperous nation into an economic disaster, while Nicolas Maduro used the BCV as a tool to remain in power and enrich himself and his corrupt circle at the expense of the Venezuelan people.

These new sanctions do not target the innocent people of Venezuela. They will not prohibit humanitarian assistance or personal remittances, which are desperately needed after years of corruption and mismanagement by the regime. In connection with these actions, the Department of the Treasury is taking several licensing-related actions that are in the interest of a democratic and prosperous Venezuela. These actions include measures to help ensure the regular processing of debit and credit card transactions, and the provision of humanitarian assistance. Licensing-related actions will also include a wind-down period for commercial operations or existing contracts involving the BCV.

The United States is committed to helping the Venezuelan people’s struggle to restore democracy and prosperity to Venezuela. By defeating Maduro’s tyranny, all Venezuelans will be free to rebuild their nation and regain the international standing and stability it deserves.

and one for Nicaragua:

Additional Financial Sanctions Against Nicaragua

Media Note

Office of the Spokesperson

Washington, DC

April 17, 2019

Today, the United States has affirmed its commitment to use all economic and diplomatic tools to promote accountability for the Ortega regime and to support the Nicaraguan people in their quest for freedom.

The United States has sanctioned Laureano Ortega and Banco Corporativo SA (Bancorp), pursuant to Executive Order 13851, which President Trump signed November 27, 2018. Because of this action, their U.S. assets are frozen and U.S. persons are generally prohibited from transactions with Laureano Ortega and Bancorp.

Laureano Ortega, son of President Daniel Ortega and Vice President Rosario Murillo, is a key enabler of the Ortega regime’s corruption. On the regime’s behalf, he has sought international financial support and foreign investment. In doing so, he has placed the interests of his family and his personal fortune ahead of the interests of the Nicaraguan people by engaging in corrupt business deals. Bancorp has served as the personal slush fund for the Ortega family and the instrument for corrupt deals with Nicolas Maduro and his former regime in Venezuela.

We urge the Ortega regime to restore democratic order in Nicaragua and heed the calls of Nicaraguans clamoring for early free, fair, and transparent elections. The regime must also abide by the commitments it has already made, including under the Inter-American Democratic Charter. We call on Nicaragua to unconditionally and fully release arbitrarily detained persons and protect the fundamental human rights of its citizens. We will continue to promote accountability for those who have demonstrated a blatant disregard for human rights and fomented violence in support of the Ortega regime.

This post is long enough already – the new General Licenses will be published separately.“

Links:

OFAC Notice

General License 3E

General License 4B

General License 9D

General License 15A

General License 16A

General License 19

General License 20

New FAQ

Treasury Press Release – Venezuela

Treasury Press Release – Nicaragua

State Department Venezuela Press Release

State Department Nicaragua Press Release

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April 15, 2019: UN, DFAT remove 1 person from counter terror list

April 22, 2019, 6:30 am
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Last Monday, Australian officials removed:

QDe.102 Name: DJAMAT HOUMAT DAAWA SALAFIA (DHDS)

A.k.a.: Djamaat Houmah Al-Dawah Al-Salafiat F.k.a.: Katibat el Ahouel Address: Algeria Listed on: 11 Nov. 2003 (amended on 26 Nov. 2004, 7 Apr. 2008, 25 Jan. 2010, 13 Dec. 2011) Other

information: Associated with the Armed Islamic Group (GIA) (QDe.006) and the Organization of

Al-Qaida in the Islamic Maghreb (QDe.014). Review pursuant to Security Council resolution 1822

(2008) was concluded on 30 Jul. 2009. INTERPOL-UN Security Council Special Notice web link:

https://www.interpol.int/en/notice/search/une/5278400 click here

from their Consolidated List’s counter terror sanctions program after his removal by the United Nations ISIL (Da’esh) and Al-Qaida Sanctions Committee.

Link:

UN Press Release

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HKMA Alert: Fraudulent HSBC website and phishing email

April 22, 2019, 6:40 am
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Press Releases

Fraudulent website and 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 fraudulent website and 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 website concerned or has conducted any financial transactions through the website 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
4 April 2019

Link:

HKMA Notice

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