The United Nations wants you to know:

NARRATIVE SUMMARIES OF REASONS

QI.C.347.15. Denis Mamadou Gerhard Cuspert

Date on which the narrative summary became available on the Committee’s website: 11 February 2015

Denis Mamadou Gerhard Cuspert was listed on 11 February 2015 pursuant to paragraphs 2 and 4 of resolution 2161 (2014) as being associated with Al-Qaida for “participating in the financing, planning, facilitating, preparing, or perpetrating of acts or activities by, in conjunction with, under the name of, on behalf of, or in support of”, “supplying, selling or transferring arms and related materiel to” and “recruiting for” Islamic State in Iraq and the Levant, listed as Al-Qaida in Iraq (QE.J.115.04).

Additional information:

Denis Mamadou Gerhard Cuspert, by acquiring training in handling firearms as well as obtaining, storing and passing firearms to others, committed a serious act of violent subversion against life, which is intended to impair and capable of impairing the existence or security of a state. Denis Cuspert is accused of murder for the attack on Sha'ar gas field, the Syrian Arab Republic on 17 July 2014 and of war crimes for killing of prisoners from the Shaitat tribe in August 2014.

After leaving Germany on 21 June 2012, Denis Cuspert travelled to the Mersa Matruh area in Egypt to undergo training in handling firearms in armed conflict at a camp for militants. This is revealed in an online video dated 10 January 2014 entitled “A meeting between a Sheikh and a Mujahid on the field of honour”. In this video clip Denis Cuspert described individual stages of his trip to the Syrian Arab Republic.

After travelling on to Libya, he continued his military training in the region around Darna with an unknown group of violent extremists. From early 2013 he trained new fighters in the Mersa Matruh area and acquired firearms and stored and passed them to the apprentice fighters for training purposes.

After his militant training, Denis Cuspert travelled to the Syrian Arab Republic on several occasions and was involved in clashes between violent extremists or rebel insurgents and Syrian government forces in Aleppo.

By at least August 2013 Denis Cuspert had joined Junud aI-Sham (not listed) and took part in battles in the Syrian coastal province of Latakia, close to the Turkish border. In August 2013, Junud al-Sham fought several battles against Syrian government forces. Among other operations the group was involved in a large-scale offensive targeting Alawite villages. Junud aI-Sham also had a presence in and to the north of the city of Aleppo. Junud al-Sham maintained close contact with AI-Nusrah Front for the People of the Levant (QE.A.137.14). It also had connections with Islamic State in Iraq and the Levant (ISIL), listed as Al-Qaida in Iraq (QE.J.115.04), and was working with both organizations in August 2013. Relations between ISIL and Junud al-Sham rapidly deteriorated; Denis Cuspert therefore left Junud al-Sham and joined ISIL by the late summer of 2013. At the end of August 2013 he was critically wounded during an air strike in the Syrian Arab Republic.

On 6 August 2013 the Junud al-Sham video entitled “Syria Latakia Sopka Durin” appeared on the Internet. The video features the organization's emir Abu aI-Walid, alias Muslim (not listed), taking viewers on a tour of the conflict zone while describing military campaigns to conquer mountain posts in the Durin region near Latakia in the period around 5 August 2013. In this video Denis Cuspert can be seen in the background several times. In another video made at the same time and in the same place as the one mentioned above, Denis Cuspert appeared openly and described previous battles for enemy posts. On 18 July 2014 three other videos were discovered on Facebook user accounts and YouTube in which Denis Cuspert can be seen or heard. The theme of the videos connected them with the ISIL conquest of the Sha’ar gas field near Homs in the Syrian Arab Republic.

With his knowledge of the goals and ideologies of the above-mentioned terrorist organizations, Denis Cuspert made his own individual support to these organizations. He also provided media support for the organisations and worked in his role as a firearms trainer for the organizations, Denis Cuspert also continued to play an active role in fighting on behalf of lSIL even after his life­ threatening injuries at the end of August 2013.

Related listed individuals and entities:

Al-Qaida (QE.A.4.01), listed on 6 October 2001

Al-Qaida in Iraq (QE.J.115.04), listed on 18 October 2004

AI-Nusrah Front for the People of the Levant (QE.A.137.14), listed on 14 May 2014

Link:

UN Narrative Summary

Posted with Blogsy

On February 13th, Her Majesty's Treasury (HMT) renewed the Final Designation for:

EUZKADI TA ASKATASUNA

a.k.a: (1) Basque Fatherland and Liberty

(2) ETA

Other Information: UK listing only
Group ID: 7083.

under the Terrorist Asset-Freezing etc. Act of 2010 for another year.

Link:

HMT Notice

Posted with Blogsy

Finnish authorities issued an email notice of a number of updates to EU sanctions, with links to the EU decisions and regulations. The dates each of them were effective is in the original Finnish text, but the links are below.

Forewarned, however – the texts are all in Finnish. Nonetheless, it does tell you which decisions are adopted by the Finns.

Links:

• Financial Sanctions
• Al-Qaeda
• Implementing Regulation 2015/64
• Implementing Regulation 2015/167
• Iran
• CFSP decision 2015/236
• Regulation 2015/229
• Implementing Regulation 2015/230
• Ivory Coast
• Implementing Regulation 2015/109
• Syria
• Implementing Regulation 2015/108
• Tunisia
• CFSP decision 2015/157
• Implementing Regulation 2015/147
• Ukraine
• CFSP decision 2015/143
• Regulation 2015/138
• CFSP decision 2015/241
• Regulation 2015/240
• Export and Import Restrictions
• Ivory Coast
• CFSP decision 2015/202
• Regulation 2015/192
• Travel Restrictions
• Al-Qaeda
• Implementing Regulation 2015/64
• Implementing Regulation 2015/167
• Iran
• CFSP decision 2015/236
• Ivory Coast
• Implementation of Decision 2015/118
• Syria
• Implementation of Decision 2015/117
• Ukraine
• CFSP decision 2015/241

Posted with Blogsy

Listed under the Al-Qaida sanctions program by the United Nations, Australian and Canadian regulators updated the following record on their Consolidated Lists:

QI.A.253.08. Name: 1: KHALIFA 2: MUHAMMAD 3: TURKI 4: AL-SUBAIY

Name (original script): خليفة محمد تركي السبيعي

Title: na Designation: na DOB: 1 Jan. 1965 POB: Doha, Qatar Good quality a.k.a.: a)Khalifa Mohd Turki Alsubaie b) Khalifa Mohd Turki al-Subaie c) Khalifa Al-Subayi d)Khalifa Turki bin Muhammad bin al-Suaiy Low quality a.k.a.: na a) Abu Mohammed al-Qatari b) Katrina Nationality: Qatari Passport no.: Qatari passport number 00685868issued in Doha on 5 Feb. 2006 and expiring on 4 Feb. 2011 National identification no.:Qatari identity card number 26563400140 Address: Doha, Qatar Listed on: 10 Oct. 2008 (amended on 25 Jan. 2010, 15 Nov. 2012, 19 Feb. 2015) Other information: Qatar-based terrorist financier and facilitator who has provided financial support to, and acted on behalf of, the senior leadership of Al-Qaida (QE.A.4.01.), including moving recruits to Al-Qaida training camps in South Asia. In Jan. 2008, convicted in absentia by the Bahraini High Criminal Court for financing terrorism, undergoing terrorist training, facilitating the travel of others to receive terrorist training abroad and for membership in a terrorist organization. Arrested in Qatar in Mar. 2008. Served his sentence in Qatar and has been released from detention. Mother’s name is Hamdah Ahmad Haidoos.

Links:

UN Notices – PDF (DFAT), HMTL (OSFI)

OSFI Notice

Posted with Blogsy

On February 20th, Her Majesty’s Treasury added the following record (which had been added a while back by the United Nations) to its Consolidated List under its Al-Qaida sanctions program:

CUSPERT, Denis, Mamadou, Gerhard

DOB: 18/10/1975. POB: Berlin, Germany a.k.a: AL-ALMANI, Abu Talha Nationality:
German National Identification no: 2550439611. German national identification
number, issued in District Friedrichshain-Kreuzberg of Berlin, Germany, issued on
22.4.2010, expires on 21.4.2020 Address: Karl-Marx-Str. 210, 12055, Berlin,
Germany. Other Information: UN Ref QI.C.347.15. Physical description: eye colour:
brown. Hair colour: black. Height: 178cm. Tattoos: BROKEN DREAMS in letters on back
and landscape of Africa on right upper arm. Father’s name: Richard Luc-Giffard.
Mother’s name: Sigrid Cuspert. Located at Syria/Turkey area (as at January 2015).
European arrest warrant issued by investigating judge at the Federal Court of Justice of
Germany, dated 14 May 2014 and 5 Dec. 2014.

after passage of Commission Implementing Regulation (EU) No 2015/274.

Links:

HMT Notice

Commission Implementing Regulation (EU) No 2015/274

Posted with Blogsy

Due to a ruling by the General Court of the European Union, the following person has been removed from the Syrian sanctions programs of the EU and the UK:

AL-TABBA, Mazen

DOB: 01/01/1958. POB: Damascus Passport Details: 004415063 (Syrian) Expires 6 May
2015 Other Information: Business partner of Ihab Makhlouf and Nizar Al-Assad. Co-
owner with Rami Makhlouf, of the Al-Diyar lil-Saraafa (a.k.a. Diar Electronic Services)
currency exchange company. Listed on: 26/03/2012 Last Updated: 20/02/2015 Group
ID: 12643.

Links:

HMT Notice

Court Decision

Posted with Blogsy

On February 24th, the Australian Department for Foreign Affairs and Trade (DFAT) listed the following group on its Consolidated List, as the result of a proclamation by the Minister of Foreign Affairs under Part 4 of the Charter of the United Nations Act 1945, which is very different than we've seen for other terror-related listings:

Ansar Bayt al-Maqdis

also known as:

Supporters of the Holy House

Ansar Jerusalem

Jihadi Jerusalem

Supporters of Jerusalem

Champions of Jerusalem

Warriors of Jerusalem

The Group of Partisans of Islamic State of Bayt Al Maqdis

Jamaat Ansar al-Dawla al-Islamiyya fi Bayt Al Maqdis

ABM

the Sinai Province

Islamic State – Sinai Province

I suspect that the reason is that this listing did not come out of the usual Al-Qaida or Taliban sanctions committees at the United Nations. You'll notice that, not only did DFAT not provide an official listing from the UN, which they normally do, that there is much less information than usual.

And, because it's unusual, here's the DFAT press release text:

The Minister for Foreign Affairs has listed the entity Ansar Bayt al-Maqdis under Part 4 of the Charter of the United Nations Act 1945 (“the Act”). The decision came into effect upon publication in the Commonwealth Government Notices Gazette on 24 February 2015. The Gazette notice is attached for your reference.

Part 4 of the Act and regulation 20 of the Charter of the United Nations (Dealing with Assets) Regulations 2008 give effect to Australia's international obligations under United Nations Security Council resolution 1373 (2001) relating to the prevention and suppression of terrorist acts. Under this legislation, the Minister for Foreign Affairs must list a person or entity if she is satisfied on reasonable grounds that the person or entity is associated with the commission of terrorist acts.

The listing makes it an offence under s. 20 of the Act to:

• use or deal with assets owned or controlled by Ansar Bayt al-Maqdis

• allow an asset owned or controlled by Ansar Bayt al-Maqdis to be used or dealt with, or

• facilitate the use of, or dealing with, an asset owned or controlled by Ansar Bayt al-Maqdis

without authorisation from the Minister for Foreign Affairs. It is also an offence under s. 21 of the Act to make an asset (of any kind) available, directly or indirectly, to the Ansar Bayt al-Maqdis without authorisation from the Minister for Foreign Affairs.

Link:

DFAT Notice

Posted with Blogsy

Australia's Autonomous Sanctions Regulations are online and pretty simple to work through. So, Mr. Watchlist is going to post interesting sections of the regulations over the next number of days and weeks.

Today, it's the list of sanctions and restrictions that can be supplied. First, here is the list of goods subject to export sanctions:

Here is the list of sanctioned services:

This is the list of categories of persons that the Minster of Foreign Affairs may designated as sanctioned:

Posted with Blogsy

On Thursday, the EU Council added 7 persons and 6 entities to those covered under the Syrian sanctions regime. As is the norm, the new names are published the next day in the Official Journal of the European Union.

The grand totals: 218 persons, 69 entities.

We'll wait until HMT adds the names this week and publishes them in their own notice, along with the name of the Implementing Regulation.

Link:

EU Press Release

Posted with Blogsy

From Part 2, Section 8:

Designation of vessels

(1) For paragraph 10 (1) (b) of the Act, the Minister may, by legislative instrument:

(a) designate a vessel as a sanctioned vessel for a country mentioned in the designation; or

(b) designate each vessel in a class of vessels as a sanctioned vessel for a country mentioned in the designation.

(2) A vessel is not required to be owned, registered or flagged by the country mentioned in the designation.

(3) A sanctioned vessel does not cease to be a sanctioned vessel solely because:

(a) its name is changed; or

(b) the flag under which it is operated changes; or

(c) its registration is changed.

Directions to sanctioned vessels

(4) The Minister may direct a sanctioned vessel to:

(a) leave Australia, including by a particular route; or

(b) not enter a particular port or place, or any port or place, in Australia.

(5) Before giving the direction, the Minister must have regard to Australia’s obligations at international law.

Next time, designations under the act – duration, revocation, etc.

Posted with Blogsy

On February 24th, Her Majesty’s Treasury (HMT) renewed the Final Designations of the following 4 persons:

for another year, under its authorities under the Terrorist Asset-Freezing etc. Act 2010 (TAFA).

Link:

HMT Notice

Posted with Blogsy

This is one case where cutting and pasting the actual regulations is largely unncessary. Simply put, a designation under the Regulation lasts for 3 years, unless renewed or revoked. One can apply for revocation of a designation, in writing stating the grounds for the revocation – but if you do it more often than yearly, the Minister is under no obligation to review the application. Applications for revocation can be made by designated persons, persons who own or control a designated asset, or persons who own or control sanctioned vessels.

Next time, the sanctions prohibitions of Part 3.

Posted with Blogsy

On Monday, OFAC designated the following 7 persons:

BENAVIDES TORRES, Antonio Jose (Latin: BENAVIDES TORRES, Antonio José); DOB 13 Jun 1961; POB Venezuela; citizen Venezuela; Gender Male; Cedula No. 6.371.374 (Venezuela); Passport 026719333 (Venezuela) expires 24 Aug 2014; Major General, Commander of the Strategic Region for the Integral Defense (REDI) of the Central Region, Venezuela's Bolivarian National Armed Forces (FANB); former Division General, Director of Operations, Venezuela's Bolivarian National Guard (GNB) (individual) [VENEZUELA].

BERNAL MARTINEZ, Manuel Gregorio (Latin: BERNAL MARTÍNEZ, Manuel Gregorio); DOB 12 Jul 1965; POB Caracas, Venezuela; nationality Venezuela; citizen Venezuela; Gender Male; Cedula No. 6.976.131 (Venezuela); Passport 0502004 (Venezuela) expires 19 Feb 2014; Brigadier General, Chief of the 31st Armored Brigade of Caracas of Venezuela's Bolivarian Army; former Director General of Venezuela's Bolivarian National Intelligence Service (SEBIN) (individual) [VENEZUELA].

GONZALEZ LOPEZ, Gustavo Enrique (Latin: GONZÁLEZ LÓPEZ, Gustavo Enrique); DOB 02 Nov 1960; POB Venezuela; nationality Venezuela; citizen Venezuela; Gender Male; Cedula No. 5.726.284 (Venezuela); Passport B0111931 (Venezuela); Director General of Venezuela's Bolivarian National Intelligence Service (SEBIN); Major General, President of Venezuela's Strategic Center of Security and Protection of the Homeland (CESPPA) (individual) [VENEZUELA].

HARINGHTON PADRON, Katherine Nayarith; DOB 05 Dec 1971; POB Caracas, Venezuela; citizen Venezuela; Gender Female; Cedula No. 10.548.414 (Venezuela); Passport 042677664 (Venezuela) expires 25 Feb 2016; National Level Prosecutor, 20th District, Venezuela's Public Ministry (individual) [VENEZUELA].

NOGUERA PIETRI, Justo Jose (Latin: NOGUERA PIETRI, Justo José); DOB 15 Mar 1961; POB Piritu, Venezuela; nationality Venezuela; citizen Venezuela; Gender Male; Cedula No. 5.944.426 (Venezuela); Passport B0942407 (Venezuela) expires 18 Dec 2006; alt. Passport 018295955 (Venezuela); President of the Venezuelan Corporation of Guayana (CVG); former Major General, General Commander of Venezuela's Bolivarian National Guard (GNB) (individual) [VENEZUELA].

PEREZ URDANETA, Manuel Eduardo (Latin: PÉREZ URDANETA, Manuel Eduardo); DOB 26 May 1962; POB Venezuela; citizen Venezuela; Gender Male; Cedula No. 6.357.038 (Venezuela); Passport 001234503 (Venezuela) expires 03 Jul 2012; Director of Venezuela's Bolivarian National Police (individual) [VENEZUELA].

VIVAS LANDINO, Miguel Alcides; DOB 08 Jul 1961; POB Venezuela; nationality Venezuela; citizen Venezuela; Gender Male; Cedula No. 7.617.778 (Venezuela); Passport B0097656 (Venezuela); Major General, Inspector General of Venezuela's Bolivarian National Armed Forces (FANB); former Commander of the Strategic Region for the Integral Defense (REDI) of the Andes Region, Venezuela's Bolivarian National Armed Forces (FANB) (individual) [VENEZUELA]. ​

under the brand-spanking new Venezuela sanctions program. It also provided a link to the Executive Order establishing the program, which targets human rights abuses and suppression of dissent.

Links:

OFAC Notice

Executive Order

Posted with Blogsy

On Monday, Her Majesty’s Treasury (HMT) implemented Council Implementing Regulation (EU) No 2015/375 by adding the following 7 individuals:

1. ABBAS, Ghassan
   Address: CERS, Centre d’Etude et de Recherche Scientifique, Centre de Recherchede Kaboun Barzar Street, PO Box 4470, Damascus. Position: Brigadier
   General Other Information: Manager of the branch of Syrian Scientific Studies andresearch Centre (SSRCC/CERS)near Jumraya/Jmraiya. CERS is also known as SSRC,Scientific Studies and Research Center. Listed on: 09/03/2015 Last Updated:09/03/2015 Group ID: 13229.

2. ABDULKARIM, Wael.
   a.k.a: AL KARIM, Wael Address: (1) Al Karim for Trade and Industry, PO Box 111,Damascus, Syria, 5797. (2) Morgan Additives Office no 2206, 22nd floor, JafzaView 19, Besides Jafza View 18, Sheikh Zayed Road, Jebel Ali Free Zone Authority,Dubai , UAE. (3) Pangates International Corp Ltd, PO Box Sharjah AirportInternational Free zone, United Arab Emirates. Other Information: ManagingDirector of the PANGATES INTERNATIONAL CORP LTD and also holds a seniorposition in AL KARIM GROUP, which is PANGATES parent company. Listed on:09/03/2015 Last Updated: 09/03/2015 Group ID: 13230.

3. BARQAWI, Ahmad
   a.k.a: BARQAWI, Ahmed Address: (1) Al Karim for Trade and Industry, PO Box111, Damascus, Syria, 5797. (2) Morgan Additives Office No 2206, 22nd floor,Jafaza View 19, Besdides Jafza View 18, Sheikh Zayed Road, Jebel Ali Free ZoneAuthority, Dubai, UAE. (3) Pangates International Corp Ltd, PO Box Sharjah AirportInternational Free Zone, United Arab Emirates. Other Information: GeneralManager of Pangates International Corp Ltd. Manager of Al Karim Group. Listedon: 09/03/2015 Last Updated: 09/03/2015 Group ID: 13231.

4. BITAR, Bayan
   a.k.a: AL-BITAR, Dr., Bayan Address: PO Box 11037, Damascus, Syria. OtherInformation: Managing Director of the Organisation for Technological Industries(OTI) and the Syrian Company for Information Technology (SCIT), which are bothsubsidiaries of the Syrian Ministry of Defence. Listed on: 09/03/2015 Last Updated:09/03/2015 Group ID: 13228.

5. HAMSHO, Emad
   Address: Hamsho Building, 31 Baghdad Street, Damascus, Syria. OtherInformation: Occupies senior management position in Hamsho Trading, asubsidiary of Hamsho International. Also known as Imad, HMISHO, HAMCHU,HAMCHO, HAMISHO, HAMEISHO and HEMASHO. Listed on: 09/03/2015 LastUpdated: 09/03/2015 Group ID: 13233.

6. HAMSHO, Samir
   Address: Hamsho Building, 31 Baghdad Street, Damascus, Syria. OtherInformation: Prominent Syrian businessman. Owner and chairman of Al Buroj andSyria Steel/Hmisho Steel, subsidiaries of Hamsho Trading, a subsidiary of HamshoInternational. Also known as Samer or Sameer, HMISHO, HAMCHU, HAMCHO,HAMISHO, HMEISHO and HEMASHO. Listed on: 09/03/2015 Last Updated:09/03/2015 Group ID: 13234.

7. HASWANI, George
   a.k.a: (1) AL HASAWANI, George (2) HASAWANI, George (3) HESWANI,
   George Address: Damascus Province, Yabroud, Al Jalaa St., Syria. OtherInformation: Prominent Syrian businessman, co-founder of HESCO Engineering andConstruction Company. Listed on: 09/03/2015 Last Updated: 09/03/2015 Group ID:13232.

and entities to the Consolidated List under its Syrian sanctions program:

1. AL BUROJ TRADING
   a.k.a: Borouj Trading Company Address: Hamsho Building, 31 Baghdad Street,Damascus, Syria. Other Information: Subsidiary of Hamsho Trading and thereforeultimately of Hamsho International. Al Buroj Trading is associated with HamshoInternational. Listed on: 09/03/2015 Last Updated: 09/03/2015 Group ID: 13239.

2. DK GROUP
   a.k.a: (1) DK Group Sarl (2) DK Middle- East & Africa Regional
   Office Address: (1) Azarieh Building, Block 03, 5th Floor Azarieh Street, SolidereDowntown, PO Box 11-503, Beirut, Lebanon. (2) DK Middle-East & Africa RegionalOffice, Peres Lazaristes Center, No. 3, 5th Floor, Emir Bachir Street, Beirut CentralDistrict, Bachoura Sector, Beirut, Lebanon. Other Information: DK Group suppliesnew banknotes to the Central Bank of Syria. Listed on: 09/03/2015 Last Updated:09/03/2015 Group ID: 13240.

3. HAMSHO TRADING
   a.k.a: (1) Hamsho Group (2) Hmisho Economic Group (3) Hmisho TradingGroup Address: Hmisho Economic Group, 31 Baghdad Street, Damascus,
   Syria. Other Information: Subsidiary of Hamsho International. Supports the Syrianregime through its subsidiaries, including Syria Steel. Listed on: 09/03/2015 LastUpdated: 09/03/2015 Group ID: 13237.

4. ORGANISATION FOR TECHNOLOGICAL INDUSTRIES
   a.k.a: Technical Industries Corporation (TIC) Address: PO Box 11037, Damascus,Syria. Other Information: Subsidiary of the Syrian Ministry of Defence. OTI isinvolved in the production of chemical weapons for the Syrian regime. Listed on:09/03/2015 Last Updated: 09/03/2015 Group ID: 13235.

5. SYRIA STEEL SA
   a.k.a: (1) Hmisho Steel (2) Syria Steel Co. (3) Syria Steel Rolling
   Mill Address: Hamsho Building, 31 Baghdad Street, Damascus, Syria. OtherInformation: Subsidiary of Hamsho Trading and therefore ultimately a subsidiary ofHamsho International. Listed on: 09/03/2015 Last Updated: 09/03/2015 Group ID:13238.

6. SYRIAN COMPANY FOR INFORMATION TECHNOLOGY (SCIT)
   Address: PO Box 11037, Damascus, Syria. Other Information: Subsidiary of theOrganisation for Technological Industries (OTI) and therefore the Syrian Ministry ofDefence. Listed on: 09/03/2015 Last Updated: 09/03/2015 Group ID: 13236.

In addition, in accordance with Council Implementing Regulation (EU) No 2015/357, the following 4 persons have been removed from the Ukraine-related sanctions:

and the following 17 listings were modified:

Links:

HMT Syria notice

Council Implementing Regulation (EU) No 2015/375

HMT Ukraine notice

Council Implementing Regulation (EU) No 2015/357

Posted with Blogsy

On February 24th, OFAC added the following individuals:

DONKO, Dejan, Na Brezno 42, Brezovica pri Ljubljani 1351, Slovenia; DOB 01 Aug 1974; POB Murska Sobota, Slovenia; nationality Slovenia; Passport P00095070 (Slovenia); Registration ID 0108974500707 (Slovenia) (individual) [SDNTK] (Linked To: PANACEA INTERNATIONAL LTD.).

KARNER, Alenka (a.k.a. HRIBAK, Alenka; a.k.a. HRIBAR, Alenka), IV-044 Rozna Dolina Cesta, Ljubljana, Slovenia; DOB 04 Sep 1978; POB Ljubljana, Slovenia; citizen Slovenia; Registration ID 0409978505053 (Slovenia) (individual) [SDNTK].

KARNER, Matevz (a.k.a. KOVAC, Matevz), Malci Beliceve 107, Ljubljana, Slovenia; DOB 19 Jul 1978; POB Ljubljana, Slovenia; nationality Slovenia; Passport P01104005 (Slovenia); Registration ID 1907978500063 (Slovenia) (individual) [SDNTK] (Linked To: BAMEX LIMITED; Linked To: PALEA D.O.O.; Linked To: KARNER D.O.O. LJUBLJANA; Linked To: PABAS HOLDING CORP.).

SLIVNIK, Uros, Malci Beliceve 36, Ljubljana, Slovenia; DOB 05 May 1979; Passport P01095514 (Slovenia) (individual) [SDNTK] (Linked To: VELINVESTMENT D.O.O.; Linked To: SAGAX INVESTMENT GROUP LTD.).

STJEPANOVIC, Savo; DOB 11 Apr 1976; POB Ljubljana, Slovenia; nationality Slovenia; Passport P00787190 (Slovenia); Registration ID 1104976500095 (Slovenia) (individual) [SDNTK] (Linked To: SIS D.O.O.; Linked To: NORTHSTAR TRADING CORPORATION).

and entities:

AMMERSHAM COMMERCIAL VENTURES LIMITED, Victoria, Seychelles; PostFach 432, Klagenfurt, Austria; Certificate of Incorporation Number 006939 (Seychelles) [SDNTK].

BAMEX LIMITED, PostFach 52, Klagenfurt 9023, Austria; Company Number 94593 (Gibraltar) [SDNTK].

KALLIOPE LIMITED, Suite 2, Portland House, Glacis Road, Gibraltar; Company Number 89681 (Gibraltar) [SDNTK].

KARNER D.O.O. LJUBLJANA, 177 V Murglah, Ljubljana 1000, Slovenia; Registration ID 5621208 (Slovenia); Tax ID No. 16437748 (Slovenia) [SDNTK].

MERIDEIS D.O.O. (f.k.a. NIPL D.O.O.), 27 Vilharjeva Cesta, Ljubljana 1000, Slovenia; Registration ID 71071784 (Slovenia) [SDNTK].

NORTH GROUP HOLDING CORP.; RUC # 1932244-1-728269 (Panama) [SDNTK].

NORTHSTAR TRADING CORPORATION (a.k.a. SYNERGY CONSULTANTS LIMITED), Victoria, Seychelles; Certificate of Incorporation Number 006971 (Seychelles) [SDNTK].

PABAS HOLDING CORP.; RUC # 1428011-1-633523 (Panama) [SDNTK].

PALEA D.O.O. (a.k.a. PALEA LTD.), 57 B Tbilisijska Ulica, Ljubljana 1000, Slovenia; Registration ID 2227843 (Slovenia); Tax ID No. SI29769221 (Slovenia) [SDNTK].

PANACEA INTERNATIONAL LTD., Copthall, P.O. Box 2331, Roseau, Dominica [SDNTK].

PANYA AG, Liechtenstein; Registration ID FL00023080583 (Liechtenstein) [SDNTK].

SAGAX INVESTMENT GROUP LTD., Suite 102, Blake Building, Corner Eyre & Hutson Street, Belize City 78583, Belize [SDNTK].

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

VELINVESTMENT D.O.O., Vilharjeva Cesta 27, Ljubljana 1000, Slovenia; Registration ID 2333970 (Slovenia); Tax ID No. SI26557576 (Slovenia) [SDNTK].

to its Specially Designated Nationals (SDN) List under its Kingpin Act anti-narcotics trafficking sanctions program.

Additionally, the following listings were removed:

FREIGHT MOVERS INTERNATIONAL, Airport Road, Basseterre, Basseterre, Saint Kitts and Nevis; Church Street, Basseterre, Basseterre, Saint Kitts and Nevis; Offices in St. Kitts and Nevins, West Indies ONLY [SDNTK].

ALBA CERDA, Salvador, Avenida Pacifico No. 2834, Seccion Costa de Oro Fraccionamiento Playas de Tijuana 22250, Tijuana, Baja California, Mexico; Avenida Pacifico No. 2408, Seccion Costa de Oro Fraccionamiento Playas de Tijuana 22250, Tijuana, Baja California, Mexico; c/o Farmacia Vida Suprema, S.A. DE C.V., Tijuana, Baja California, Mexico; c/o Distribuidora Imperial De Baja California, S.A. DE C.V., Tijuana, Baja California, Mexico; c/o ADP, S.C., Tijuana, Baja California, Mexico; DOB 25 Dec 1947; POB Patzcuaro, Michoacan; Credencial electoral 125324910951 (Mexico) (individual) [SDNTK].

and the following was changed:

KARNER, Mihael (a.k.a. TOPOLOVEC, Jozef), Locnikarijeva ulica 7, 1000, Ljubljana, Slovenia; Rozna Dolina, Cesta IV 44, Ljubljana, Slovenia; V Murglah 177, Ljubljana, Slovenia; DOB 13 Mar 1975; POB Ljubljana, Slovenia; nationality Slovenia; Passport PZ2420022110 (Slovenia); alt. Passport PB06005902 (Slovenia); Personal ID Card 00246412491303975500493 (Slovenia) expires 17 Dec 2018; alt. Personal ID Card 002464124 (Slovenia) expires 17 Dec 2018 (individual) [SDNTK]. -to- KARNER, Mihael (a.k.a. TOPOLOVEC, Jozef), Locnikarijeva ulica 7, 1000, Ljubljana, Slovenia; Rozna Dolina, Cesta IV 44, Ljubljana, Slovenia; V Murglah 177, Ljubljana, Slovenia; DOB 13 Mar 1975; POB Ljubljana, Slovenia; nationality Slovenia; Passport PZ2420022110 (Slovenia); alt. Passport PB06005902 (Slovenia); Personal ID Card 00246412491303975500493 (Slovenia) expires 17 Dec 2018; alt. Personal ID Card 002464124 (Slovenia) expires 17 Dec 2018 (individual) [SDNTK] (|Linked To: MERIDEIS D.O.O.; Linked To: PANYA AG; Linked To: VELINVESTMENT D.O.O.; Linked To: SAGAX INVESTMENT GROUP LTD.; Linked To: KALLIOPE LIMITED; Linked To: KARNER D.O.O. LJUBLJANA; Linked To: NORTHSTAR TRADING CORPORATION; Linked To: AMMERSHAM COMMERCIAL VENTURES LIMITED; Linked To: NORTH GROUP HOLDING CORP.|).

Link:

OFAC Notice

Posted with Blogsy

Yesterday, OFAC designated the following persons under the Ukraine-related sanctions program (related to Executive Order 13660):

ABISOV, Sergei (a.k.a. ABISOV, Sergei Vadimovich); DOB 27 Nov 1967; POB Simferopol, Crimea, Ukraine (individual) [UKRAINE-EO13660].

ARBUZOV, Serhiy (a.k.a. ARBUZOV, Sergey G.; a.k.a. ARBUZOV, Serhiy Hennadiyovych); DOB 24 Mar 1976; POB Donetsk, Ukraine; Former First Deputy Prime Minister of Ukraine (individual) [UKRAINE-EO13660].

AZAROV, Mykola Yanovych (a.k.a. AZAROV, Mykola Nikolai Yanovych; a.k.a. PAKHLO, Nikolai Yanovich); DOB 17 Dec 1947; POB Kaluga, Russia; Former Prime Minister of Ukraine (individual) [UKRAINE-EO13660].

BOHATYRIOVA, Raisa Vasylivna (a.k.a. BOGATYRIOVA, Raisa; a.k.a. BOGATYROVA, Raisa; a.k.a. BOGATYRYOVA, Raisa; a.k.a. BOHATYREVA, Raisa; a.k.a. BOHATYROVA, Raisa; a.k.a. BOHATYRYOVA, Raisa; a.k.a. BOHATYRYOVA, Rayisa); DOB 06 Jan 1953; POB Bakal, Chelyabinsk, Russia (individual) [UKRAINE-EO13660].

DUGIN, Aleksandr (a.k.a. DUGIN, Aleksandr Gelyevich; a.k.a. DUGIN, Alexander Gelyevich); DOB 07 Jan 1962 (individual) [UKRAINE-EO13660].

GUBAREVA, Ekaterina (a.k.a. GUBAREVA, Yekaterina); DOB 05 Jul 1983 (individual) [UKRAINE-EO13660].

IVAKIN, Yuriy Vladimirovich (a.k.a. IVAKIN, Yurii); DOB 13 Aug 1954; POB Perevalsk, Ukraine (individual) [UKRAINE-EO13660].

KANISHCHEV, Pavel; DOB 1986 (individual) [UKRAINE-EO13660].

KARAMAN, Aleksandr (a.k.a. CARAMAN, Aleksandru; a.k.a. KARAMAN, Alexander; a.k.a. KARAMAN, Oleksandr); DOB 26 Jul 1956; POB Republic of Mordovia, Russia (individual) [UKRAINE-EO13660].

KHODAKOVSKYY, Oleksandr Sergeyevich (a.k.a. KHODAKOVSKIY, Aleksandr; a.k.a. KHODAKOVSKY, Alexander); DOB 18 Dec 1972; POB Donetsk, Ukraine (individual) [UKRAINE-EO13660].

KOVALENKO, Andrey; DOB 30 Dec 1985 (individual) [UKRAINE-EO13660].

KOZYURA, Oleg Grigorievich (a.k.a. KOZYURA, Oleg Grigoryevich); DOB 19 Dec 1962; POB Zaporozhye, Ukraine; Head of the Office of the Federal Migration Service in the City of Sevastopol (individual) [UKRAINE-EO13660].

LYAGIN, Roman (a.k.a. LIAGIN, Roman; a.k.a. LIAHIN, Roman; a.k.a. LYAHIN, Roman); DOB 30 May 1980; POB Donetsk, Ukraine (individual) [UKRAINE-EO13660].

ZDRILIUK, Serhii Anatoliyovych (a.k.a. ZDRILIUK, Serghiei; a.k.a. ZDRILYUK, Sergei; a.k.a. ZDRILYUK, Sergey; a.k.a. ZDRYLYUK, Serhiy); DOB 23 Jun 1972; POB Vinnytsia Region, Ukraine; nationality Ukraine; citizen Russia (individual) [UKRAINE-EO13660].

and one entity:

EURASIAN YOUTH UNION, Russia 3, Bagrationovskiy Proezd, House 7, Area 20 B, Office 405, Moscow 121087, Russia; Website http://rossia3.ru; Email Address esm@rossia3.ru [UKRAINE-EO13660].

In addition, they also added one firm to the Crimean part of the sanctions program (under Executive Order 13685):

RUSSIAN NATIONAL COMMERCIAL BANK (a.k.a. RNKB OAO; a.k.a. ROSSISKI NATSIONALNY KOMMERCHESKI BANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. “RNCB”), d. 9 korp. 5 ul.Krasnoproletarskaya, Moscow 127030, Russia; SWIFT/BIC RNCO RU MM; Website http://www.rncb.ru; Email Address rncb@rncb.ru; BIK (RU) 044525607; Registration ID 1027700381290 (Russia); Tax ID No. 7701105460 (Russia); Government Gazette Number 09610705 (Russia) [UKRAINE-EO13685].

Links:

OFAC Notice

Posted with Blogsy

On Tuesday, Her Majesty's Treasury, in accordance with Council Implementing Regulation (EU) No 2015/376, modified the following listing on its Consolidated List:

ABDULHAFIZ, Mas'ud

Title: Colonel DOB: 01/01/1937. POB: Tripoli, Libya a.k.a: ABDULHAFID,
Massoud Position: Armed Forces Commander Other Information: EU listing. Not
UN. 3rd in command of Armed Forces. Significant role in Military Intelligence.
Listed on: 03/03/2011 Last Updated: 10/03/2015 Group ID: 11641.

under the Libyan sanctions program.

In addition, the following person:

QADHAF AL-DAM, Ahmed, Mohammed

DOB: –/–/1952.

POB: Egypt

Other Information: EU listing. Not UN. Cousin of Muammar Qadhafi. Since 1995, he is
believed to have had command of an elite army battalion in charge of Qadhafi's
personal security and to have a key role in External Security Organisation. He has been
involved in planning operations against Libyan dissidents abroad and was directly
involved in terrorist activity.

has been removed from the Libyan sanctions regulation, having been previously removed as the result of a court decision.

Links:

HMT Notice

Delisting Notice

Council Implementing Regulation (EU) No 2015/376

Posted with Blogsy

Extension of Timeframe for the Termination of Independent Data Files for the FSE, SSI and NS-PLC Lists and Migration to the Consolidated Sanctions List Data Files

2/25/2015

​On October 10, 2014, OFAC released the following announcement:

“In approximately 6 months, OFAC will cease issuing independent data files for the FSE List, the SSI List and the NS-PLC List. During the transition period, OFAC will produce these data on both the Consolidated Sanctions List and on the appropriate individual lists. The new Consolidated Sanctions List data files can be accessed on this page​. In addition, the Consolidated Sanctions List data files are available on OFAC’s File Transfer Protocol (FTP) site at ftp://ofacftp.treas.gov in a folder called, “consolidated_list.” Please visit the Consolidated Sanctions List Specification filefor the information about data file nomenclature, column headers and field widths. The XSD specification file for the XML version of the Consolidated Sanctions List may be found here.

OFAC will continue to provide and update independent human readable (.pdf and .txt) versions of the FSE, SSI, NS-ISA, NS-PLC and Part 561 lists and their respective archive of changes files. These file formats will not be affected by the creation of the consolidated data files and will continue to be available even after the transition period.“

In response to public requests, OFAC is extending its support period for the independent data files for the FSE List, the SSI List and the NS-PLC List by an additional three (3) months. The support period for these files will now end on or about July 10, 2015.

Link:

OFAC Notice

Posted with Blogsy

On February 26th, OFAC added the following 3 persons:

FAWAZ, Fouzi Reda Darwish (a.k.a. DARWISH-FAWAZ, Fawzy Reda; a.k.a. DARWISH-FAWAZ, Fouzi Reda; a.k.a. FAWAZ, Fawzi Reda; a.k.a. FAWAZ, Fawzy; a.k.a. FAWAZ, Fowzy; a.k.a. FAWWAZ, Fawzi); DOB 12 Feb 1968; alt. DOB 24 Mar 1973; POB Jwaya, Lebanon; alt. POB Sierra Leone; citizen Lebanon; alt. citizen Nigeria; alt. citizen Sierra Leone; Passport 0107516 (Lebanon); alt. Passport 0258649 (individual) [SDGT] (Linked To: HIZBALLAH).

FAWAZ, Mustapha Reda Darwish (a.k.a. DARWISH-FAWAZ, Moustafa Reda; a.k.a. FAWAZ, Mostafa Reda Darwich; a.k.a. FAWAZ, Moustapha; a.k.a. FAWAZ, Mustafa; a.k.a. FAWAZ, Mustafa Darwish; a.k.a. FAWAZ, Mustapha; a.k.a. FAWAZ, Mustapha Rhoda Darwich; a.k.a. FAWAZ, Mustapha Rida Darwich; a.k.a. FAWWAZ, Mustafa), Flat 4, Blantyre Street, Behind Amigo Supermarket, Wuse II, Abuja, Nigeria; 3 Gaya Road, Kano, Nigeria; DOB 25 Jun 1964; alt. DOB 10 Sep 1964; POB Jwaya, Lebanon; alt. POB Koidu Town, Sierra Leone; citizen Lebanon; alt. citizen Nigeria; alt. citizen Sierra Leone; Gender Male; Passport RL 2101602 (Lebanon); alt. Passport RL 0148105 (Lebanon); alt. Passport 0168459 (Sierra Leone); alt. Passport 0257909 (Sierra Leone); SSN 418-15-2837 (United States) (individual) [SDGT] (Linked To: HIZBALLAH).

TAHINI, Abdallah Asad (a.k.a. THAHINI, Abdallah; a.k.a. THINI, Abdalla As'ad; a.k.a. “TAHINI, Ahmad”); DOB 20 Jun 1965; POB Lebanon (individual) [SDGT] (Linked To: HIZBALLAH).

and three entities:

AMIGO SUPERMARKET LIMITED (a.k.a. AMIGO SUPERMARKET), 1023, Adetokunbo Ademola Crescent, Wuse II, Abuja, Nigeria [SDGT] (Linked To: FAWAZ, Mustapha Reda Darwish; Linked To: FAWAZ, Fouzi Reda Darwish).

KAFAK ENTERPRISES LIMITED, 88B, T/Balewa Road, Kano State, Nigeria; Sierra Leone [SDGT] (Linked To: FAWAZ, Mustapha Reda Darwish; Linked To: FAWAZ, Fouzi Reda Darwish).

WONDERLAND AMUSEMENT PARK AND RESORT LTD (a.k.a. WONDERLAND AMUSEMENT PARK), B1 Kukbawa, Opposite National Stadium, Abuja, FCT, Nigeria [SDGT] (Linked To: FAWAZ, Mustapha Reda Darwish; Linked To: FAWAZ, Fouzi Reda Darwish).

and removed the following:

BANK AL TAQWA LIMITED (a.k.a. AL TAQWA BANK; a.k.a. BANK AL TAQWA), P.O. Box N-4877, Nassau, Bahamas, The; c/o Arthur D. Hanna & Company, 10 Deveaux Street, Nassau, Bahamas, The [SDGT].

BANK AL TAQWA (a.k.a. AL TAQWA BANK; a.k.a. BANK AL TAQWA LIMITED), P.O. Box N-4877, Nassau, Bahamas, The; c/o Arthur D. Hanna & Company, 10 Deveaux Street, Nassau, Bahamas, The [SDGT].

AL TAQWA BANK (a.k.a. BANK AL TAQWA; a.k.a. BANK AL TAQWA LIMITED), P.O. Box N-4877, Nassau, Bahamas, The; c/o Arthur D. Hanna & Company, 10 Deveaux Street, Nassau, Bahamas, The [SDGT].

NADA MANAGEMENT ORGANIZATION SA (f.k.a. AL TAQWA MANAGEMENT ORGANIZATION SA), Viale Stefano Franscini 22, Lugano CH-6900 TI, Switzerland [SDGT].

AL TAQWA MANAGEMENT ORGANIZATION SA (a.k.a. NADA MANAGEMENT ORGANIZATION SA), Viale Stefano Franscini 22, Lugano CH-6900 TI, Switzerland [SDGT].

YOUSSEF M. NADA & CO. GESELLSCHAFT M.B.H. (a.k.a. YOUSSEF M. NADA AND CO. GESELLSCHAFT M.B.H.), Kaernter Ring 2/2/5/22, Vienna 1010, Austria [SDGT].

YOUSSEF M. NADA AND CO. GESELLSCHAFT M.B.H. (a.k.a. YOUSSEF M. NADA & CO. GESELLSCHAFT M.B.H.), Kaernter Ring 2/2/5/22, Vienna 1010, Austria [SDGT].

YOUSSEF M. NADA, Via Riasc 4, Campione d'Italia I CH-6911, Switzerland [SDGT].

WALDENBERG, AG (f.k.a. AL TAQWA TRADE, PROPERTY AND INDUSTRY; f.k.a. AL TAQWA TRADE, PROPERTY AND INDUSTRY COMPANY LIMITED; f.k.a. AL TAQWA TRADE, PROPERTY AND INDUSTRY ESTABLISHMENT; f.k.a. HIMMAT ESTABLISHMENT), c/o Asat Trust Reg., Altenbach 8, Vaduz 9490, Liechtenstein; Via Posero, 2, Compione d'Italia 22060, Italy [SDGT].

HIMMAT ESTABLISHMENT (f.k.a. AL TAQWA TRADE, PROPERTY AND INDUSTRY; f.k.a. AL TAQWA TRADE, PROPERTY AND INDUSTRY COMPANY LIMITED; f.k.a. AL TAQWA TRADE, PROPERTY AND INDUSTRY ESTABLISHMENT; a.k.a. WALDENBERG, AG), c/o Asat Trust Reg., Altenbach 8, Vaduz 9490, Liechtenstein; Via Posero, 2, Compione d'Italia 22060, Italy [SDGT].

AL TAQWA TRADE, PROPERTY AND INDUSTRY ESTABLISHMENT (f.k.a. AL TAQWA TRADE, PROPERTY AND INDUSTRY; f.k.a. AL TAQWA TRADE, PROPERTY AND INDUSTRY COMPANY LIMITED; f.k.a. HIMMAT ESTABLISHMENT; a.k.a. WALDENBERG, AG), c/o Asat Trust Reg., Altenbach 8, Vaduz 9490, Liechtenstein; Via Posero, 2, Compione d'Italia 22060, Italy [SDGT].

AL TAQWA TRADE, PROPERTY AND INDUSTRY (f.k.a. AL TAQWA TRADE, PROPERTY AND INDUSTRY COMPANY LIMITED; f.k.a. AL TAQWA TRADE, PROPERTY AND INDUSTRY ESTABLISHMENT; f.k.a. HIMMAT ESTABLISHMENT; a.k.a. WALDENBERG, AG), c/o Asat Trust Reg., Altenbach 8, Vaduz 9490, Liechtenstein; Via Posero, 2, Compione d'Italia 22060, Italy [SDGT].

AL TAQWA TRADE, PROPERTY AND INDUSTRY COMPANY LIMITED (f.k.a. AL TAQWA TRADE, PROPERTY AND INDUSTRY; f.k.a. AL TAQWA TRADE, PROPERTY AND INDUSTRY ESTABLISHMENT; f.k.a. HIMMAT ESTABLISHMENT; a.k.a. WALDENBERG, AG), c/o Asat Trust Reg., Altenbach 8, Vaduz 9490, Liechtenstein; Via Posero, 2, Compione d'Italia 22060, Italy [SDGT].

ASAT TRUST REG., Altenbach 8, Vaduz 9490, Liechtenstein [SDGT].

NADA, Youssef (a.k.a. NADA, Youssef M.; a.k.a. NADA, Youssef Mustafa), Via Per Arogno 32, Compione d'Italia CH-6911, Switzerland; Via Arogno 32, Compione d'Italia CH-6911, Italy; Via Riasc 4, Compione d'Italia CH-6911, Switzerland; DOB 17 May 1931; alt. DOB 17 May 1937; POB Alexandria, Egypt; citizen Tunisia (individual) [SDGT].

NADA, Youssef M. (a.k.a. NADA, Youssef; a.k.a. NADA, Youssef Mustafa), Via Per Arogno 32, Compione d'Italia CH-6911, Switzerland; Via Arogno 32, Compione d'Italia CH-6911, Italy; Via Riasc 4, Compione d'Italia CH-6911, Switzerland; DOB 17 May 1931; alt. DOB 17 May 1937; POB Alexandria, Egypt; citizen Tunisia (individual) [SDGT].

NADA, Youssef Mustafa (a.k.a. NADA, Youssef; a.k.a. NADA, Youssef M.), Via Per Arogno 32, Compione d'Italia CH-6911, Switzerland; Via Arogno 32, Compione d'Italia CH-6911, Italy; Via Riasc 4, Compione d'Italia CH-6911, Switzerland; DOB 17 May 1931; alt. DOB 17 May 1937; POB Alexandria, Egypt; citizen Tunisia (individual) [SDGT].

BA TAQWA FOR COMMERCE AND REAL ESTATE COMPANY LIMITED (n.k.a. HOCHBURG, AG), Vaduz, Liechtenstein; formerly c/o Asat Trust reg., Vaduz, Liechtenstein [SDGT].

HOCHBURG, AG (a.k.a. BA TAQWA FOR COMMERCE AND REAL ESTATE COMPANY LIMITED), Vaduz, Liechtenstein; formerly c/o Asat Trust reg., Vaduz, Liechtenstein [SDGT].

NADA INTERNATIONAL ANSTALT, Vaduz, Liechtenstein; formerly c/o Asat Trust reg., Vaduz, Liechtenstein [SDGT].

from the SDN List's anti-terror sanctions.

Links:

OFAC Notice

Posted with Blogsy

Everyone gets a piece of the pie here – the NY Department of Financial Services gets $610 million, OFAC’s official fine is in excess of $250 million (but is deemed paid on the basis of the lesser amount paid to the Department of Justice). All told, it’s another mega-fine of $1.45 billion dollars for conduct breaching the Iran, Weapons of Mass Destruction, Sudan, Burma and Cuba sanctions programs from 2002 until 2010.

Here is how OFAC saw matters in knocking down the penalty from a base of over $574 million:

The following were found to be aggravating factors:

• At a minimum,Commerzbank acted with reckless disregard for U.S. sanctions requirements in processingtransactions in apparent violation of OFAC sanctions regulations;
• management at Commerzbankknew or had reason to know of the conduct leading to certain of the apparent violations;
• theconduct described above conferred significant economic benefit to persons subject to U.S.sanctions and undermined the integrity of multiple U.S. sanctions programs;
• Commerzbank is alarge, commercially sophisticated financial institution; and
• Commerzbank did not maintainadequate policies or procedures to ensure compliance with the sanctions programs administeredby OFAC.

Mitigation was extended because

• Commerzbank has not received a penalty notice orFinding of Violation from OFAC in the five years preceding the date of the earliest transactiongiving rise to the apparent violations;
• Commerzbank cooperated with OFAC’s investigation ofthe apparent violations by engaging in an extensive internal investigation, by responding forrequests for information, and by executing a statute of limitations tolling agreement withmultiple extensions; and
• Commerzbank took remedial action in response to the apparentviolations described above.

The NY DFS was also able to extract, in return for settling the charges, the termination of multiple employees and the installation of an independent monitor at Commerzbank.

Links:

OFAC Notice

OFAC Enforcement Action

Treasury Department Settlement

Treasury Department Press Release

NY DFS Press Release

Posted with Blogsy