44. Is Cuba open for U.S. business and investment?

Persons subject to U.S. jurisdiction are prohibited from doing business or investing in Cubaunless licensed by OFAC. An OFAC general license authorizes the exportation from the UnitedStates, and the reexportation of 100% U.S.-origin items from third-countries, to Cuba only inthose cases where the exportation or reexportation is licensed or otherwise authorized by theCommerce Department. The Commerce Department currently authorizes limited categories ofitems to be exported or reexported to Cuba.

45. Can U.S. trade delegations travel to Cuba?

Trade delegations are authorized to travel to Cuba only if each member of the delegation meetsthe criteria of an applicable general license authorizing travel to Cuba or has obtained a specificlicense from OFAC. Authorized trade delegations generally fall under one of two generallicenses for travel authorization; either (1) 31 CFR § 515.533(d), which authorizes travel-relatedand other transactions incident to the exportation of certain authorized goods from the U.S. toCuba, specifically the conduct of “market research, commercial marketing, sales negotiation,accompanied delivery, or servicing in Cuba of items consistent with the export or report licensingpolicy of the Commerce Department,” or (2) 31 C.F.R. § 515.564(a), which authorizestransactions related to professional research or professional meetings in Cuba. For a completedescription of what these general licenses authorize and the restrictions that apply, please see 31CFR §§ 515.533(d) and 515.564(a).

Neither of the aforementioned general licenses authorizes the establishment of a permanentphysical presence in Cuba.

46. Are insurers allowed to provide travel insurance for authorized travel to Cuba?

Yes. See 31 CFR § 515.560.

47. May U.S. insurers issue policies and pay claims related to group health, life, and travelinsurance on behalf of third-country nationals traveling to or within Cuba?

Yes, provided that the insurance policy is as global policy. Section 515.580 of the CACRauthorizes persons subject to U.S. jurisdiction to issue or provide global health, life, or travelinsurance policies for individuals ordinarily resident in a country outside of Cuba who travel to orwithin Cuba, regardless of whether the insurance policy is issued only to that individual or to agroup, such as to all employees of a particular company. For instance, a U.S. insurer may paymedical claims pursuant to a group health insurance policy to or on behalf of a covered third-country national injured while traveling in Cuba. However, this provision does not authorize aperson subject to U.S. jurisdiction to issue an insurance policy that is specific to travel to Cuba. A separate provision of the CACR, 31 CFR § 515.560, authorizes the provision of health,life, and travel insurance-related services for authorized U.S. travelers.

48. Are insurance policies that are issued to a “group” (e.g., an employer and its employees)authorized by the CACR?

Section 515.580 of the CACR authorizes global insurance policies covering individuals ordinarilyresident in a country outside of Cuba traveling to Cuba. The policy may be issued to a group,such as all employees of a company. The “global” requirement means it cannot be specific totravel to Cuba. For example, it does not authorize an individual travel policy issued to a travelerspecifically to cover a planned trip to Cuba. It also does not authorize issuing a policy to a non-U.S. travel agent specifically to cover its traveler clients where the travel agency is solely in thebusiness of planning trips to Cuba.

49. What types of Cuban-origin goods are authorized for importation into the United States?

Persons subject to U.S. jurisdiction authorized to travel to Cuba may import into the United Statesas accompanied baggage merchandise acquired in Cuba with a value not to exceed $400 perperson, including no more than $100 in alcohol and tobacco products.Persons subject to U.S. jurisdiction are also authorized to import certain goods produced byindependent Cuban entrepreneurs as determined by the State Department, to be set forth in theState Department’s Section 515.582 list.

The importation into the United States from Cuba of information and informational materials isexempt from the prohibitions of the Cuban Assets Control Regulations. The definition of“information and informational materials” may be found at 31 CFR § 515.332.

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From the United Nations Narrative Summary:

QDi.354 Tarak ben Taher ben Faleh Ouni Harzi

Date on which the narrative summary became available on the Committee’s website: 10 April 2015

Tarak ben Taher ben Faleh Ouni Harzi was listed on 10 April 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” and “recruiting for Ansar al-Shari’a in Tunisia (AAS-T) (QDe.143) and Islamic State in Iraq and the Levant, listed as Al-Qaida in Iraq (QDe.115).

Additional information:

Tarak ben Taher ben Faleh Ouni Harzi has been a dangerous and active terrorist element within Al-Qaida in Iraq (QDe.115) since 2004 before being arrested in 2006 and imprisoned in Abu Ghraib prison. He managed to escape in 2013 following the attack by Al-Qaida in Iraq. Tarak Harzi is located in Syria where he is active in the facilitation and the hosting of Ansar al-Shari’a in Tunisia (AAS-T) (QDe.143) members in this country, in coordination with his brother Ali ben Taher ben Faleh Ouni Harzi (QDi.353) (a notorious AAS-T member).

On 30 October 2007, Tarak Harzi was sentenced in absentia to 24 years imprisonment.

Related listed individuals and entities:

Al-Qaida (QDe.004), listed on 6 October 2001

Al-Qaida in Iraq (QDe.115), listed on 18 October 2004

Ansar al-Shari’a in Tunisia (QDe.143), listed on 23 September 2014

Ali ben Taher ben Faleh Ouni Harzi (QDi.353), listed on 10 April 2015

Link:

UN Narrative Summary

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50. What types of telecommunications and internet-based services are authorized under
general license?

OFAC has issued an expanded general license which, subject to appropriate conditions, generally
authorizes transactions that establish mechanisms to provide commercial telecommunications
services in Cuba or linking third countries and Cuba. OFAC has also updated the general licenses
authorizing telecommunications-related transactions, including payment related to the provision
of telecommunications involving Cuba or provided to Cuban individuals. Pursuant to this
provision, U.S. persons may, for example, purchase calling cards for people to use in Cuba and/or
may pay the bills of such people directly to a telecommunications operator located in Cuba, such
as ETECSA. These steps to facilitate improved access to telecommunications services for
Cubans and increased international connections are intended to increase the ability of the Cuban
people to communicate freely and to better provide for efficient and adequate telecommunications
services between the United States and Cuba. For a complete description of what this general
license authorizes and the restrictions that apply, please see 31 CFR § 515.542.

Persons subject to U.S. jurisdiction may provide additional services incident to internet-based
communications and related to certain authorized exportations and reexportations of
communications items. The range of such services has been expanded to coincide with changes
to Commerce Department regulations, and such services can now be provided for a fee to certain
end users. For example, transactions incident to providing fee-based internet communications
services such as e-mail or other messaging platforms, social networking, VOIP, web-hosting, or
domain-name registration are now authorized in most circumstances. Services related to many
kinds of software (including applications) used on personal computers, cell phones, and other
personal communications devices are also authorized, along with other services related to the use
of such devices. Finally, services such as cloud storage, software design, business consulting,
and the provision of IT management and support related to use of hardware and software
exported or reexported to Cuba pursuant to the Commerce Department’s Consumer
Communications Device authorization is permitted. For a complete description of what this
general license authorizes and the restrictions that apply, please see 31 CFR § 515.578.

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Yesterday, Swiss regulators added the following 2 people to the Yemen sanctions program in their Consolidated List:

SSID: 85-31216 Foreign identifier: YEi.004 Name: Abdulmalik Al-Houti

Justification: Abdulmalik al-Houthi was designated for sanctions on 14 Apr 2015 pursuant
to paragraphs 11 and 15 of resolution 2140 (2014) and paragraph 14 of resolution 2216
(2015). Other information: a) Abdul Malik al Houthi is a leader of a group that has engaged
in acts that threaten the peace, security, or stability of Yemen. b) In Sep 2014, Houthi forces
captured Sanaa and in Jan 2015 they attempted to unilaterally replace the legitimate
government of Yemen with an illegitimate governing authority that the Houthis dominated.
Al-Houthi assumed the leadership of Yemen’s Houthi movement in 2004 after the death of
his brother, Hussein Badredden al-Houthi. As leader of the group, al-Houthi has repeatedly
threatened Yemeni authorities with further unrest if they do not respond to his demands and
detained President Hadi, Prime Minister, and key cabinet members. Hadi subsequently
escaped to Aden. The Houthis then launched another offensive towards Aden assisted by
military units loyal to former president Saleh and his son, Ahmed Ali Saleh. Modifications:
Listed on 5 May 2015

SSID: 85-31222 Foreign identifier: YEi.005 Name: Ahmed Ali Abdullah Saleh
Justification: Ahmed Ali Abdullah Saleh was designated for sanctions on 14 Apr 2015
pursuant to paragraphs 11 and 15 of resolution 2140 (2014) and paragraph 14 of resolution
2216 (2015). Relation: Son of Ali Abdullah Saleh (YEi.003, SSID 85-29644) Other
information: a) Ahmed Ali Saleh has engaged in acts that threaten the peace, security, and
stability of Yemen. b) Ahmed Ali Saleh has been working to undermine President Hadi’s
authority, thwart Hadi’s attempts to reform the military, and hinder Yemen’s peaceful
transition to democracy. Saleh played a key role in facilitating the Houthi military expansion.
As of mid-Feb 2013, Ahmed Ali Saleh had issued thousands of new rifles to Republican
Guard brigades and unidentified tribal shaykhs. The weapons were originally procured in
2010 and reserved to purchase the loyalties of the recipients for political gain at a later date.
c) After Saleh’s father, former Republic of Yemen President Ali Abdullah Saleh, stepped
down as President of Yemen in 2011, Ahmed Ali Saleh retained his post as commander of
Yemen’s Republican Guard. A little over a year later, Saleh was dismissed by President
Hadi but he retained significant influence within the Yemeni military, even after he was removed from command. Ali Abdullah Saleh was designated by the UN under UNSCR 2140
in Nov 2014. Modifications: Listed on 5 May 2015

The Watchlists page will be updated shortly.

Links:

FINMA Notice

Data files of updates – PDF, XML

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On Tuesday, OFAC issued a guidance document clarifying the travel restrictions in place with regard to the loosened Cuban sanctions.

Question 1:

Which individuals may be transported between the United States and Cuba by a person
that qualifies for the general license to provide carrier services via aircraft or that has
received a specific license to provide carrier services via commercial passenger vessel?

 Persons subject to U.S. jurisdiction who are traveling to/from Cuba pursuant to a general
license under one of the 12 categories of travel listed in section 515.560 of the CACR or
under a specific license from OFAC may be transported via aircraft or commercial
passenger vessel between the United States and Cuba.
 Cuban nationals applying for admission to the United States, as well as third-country
nationals, with a valid visa or other travel authorization issued by the U.S. government
may be transported via aircraft or commercial passenger vessel to the United States from
Cuba; Cuban nationals present in the United States in a non-immigrant status or pursuant
to other non-immigrant travel authorization issued by the U.S. government may be
transported via aircraft or commercial passenger vessel from the United States to Cuba.
Cuban nationals who have taken up residence in the United States and are licensed as
unblocked nationals pursuant to 31 C.F.R. § 515.505(a)(1) are persons subject to U.S.
jurisdiction and may be transported to Cuba if they meet the criteria set out in the first
bullet above.
 An individual, including a foreign national, who is traveling on official business of the
U.S. government, a foreign government, or an intergovernmental organization of which
the United States is a member or in which the United States holds observer status –
including an employee, contractor, or grantee of such government or intergovernmental
organization and any individual traveling on a diplomatic passport – as well as any close
relative accompanying the traveler may be transported via aircraft or commercial
passenger vessel between the United States and Cuba.
Section 515.572 of the CACR authorizes persons subject to U.S. jurisdiction to provide carrier
services by aircraft to, from, or within Cuba, in connection with travel authorized pursuant to the
CACR. This authorization does not apply to carrier services by commercial passenger vessel,
which would require a specific license from OFAC. Additionally, separate authorization from
Commerce Department’s Bureau of Industry and Security (BIS) is required for the temporary
sojourn to Cuba of both aircraft and vessels. Persons engaging in these activities may require
additional authorizations by other U.S. government agencies. Persons subject to U.S.
jurisdiction providing travel or carrier services pursuant to an OFAC general or specific license
shall be required to retain for at least five years from the date of the transaction a certification
from each customer indicating the section of the CACR, or the specific license, that authorizes
the person to travel to Cuba.

Question 2:

What type of cargo may a person authorized to provide carrier services via aircraft or
commercial passenger vessel transport from the United States to Cuba?

Section 515.533 of the CACR authorizes all transactions ordinarily incident to the export to
Cuba of items licensed or otherwise authorized by BIS. Accordingly, a person providing carrier
services for authorized travelers going from the United States to Cuba may transport cargo and
baggage accompanying an authorized traveler provided that the export of the cargo and baggage
is authorized by BIS. Additionally, a person providing carrier services for authorized travelers
going from the United States to Cuba may transport other cargo or unaccompanied baggage
whose export to Cuba is licensed or otherwise authorized by BIS. See § 515.533.

The exportation of information and informational materials, as defined in section 515.332 of the
CACR, to Cuba from the United States is exempt from the prohibitions of the CACR.

Question 3:

What type of cargo may a person authorized to provide carrier services via aircraft or
commercial passenger vessel transport directly from Cuba to the United States?

Under the CACR, an authorized traveler departing Cuba for the United States may carry as
accompanied baggage:

 For persons subject to U.S. jurisdiction, up to $400 of merchandise acquired in Cuba for
personal use, of which up to $100 may be alcohol or tobacco products.
 For foreign nationals, any Cuban-origin goods other than alcohol or tobacco products,
provided that such goods are not in commercial quantities and are not imported for
resale, as authorized by 31 CFR § 515.569, and up to $100 in alcohol/tobacco products
acquired in Cuba for personal use (see note to 31 C.F.R. § 515.569).
 All travelers may carry goods produced by Cuban entrepreneurs as authorized by 31
CFR § 515.582 and the State Department’s 515.582 List (available at
http://www.state.gov/e/eb/tfs/spi).
 For a traveler who left the United States for Cuba and is now returning to the United
States, any items the traveler temporarily exported to Cuba pursuant to a BIS license or
other authorization.
Additionally, persons authorized to provide carrier services via aircraft or commercial passenger
vessel may transport from Cuba to the United States cargo, other than accompanied baggage, the
importation of which has been authorized by general or specific license, as well as by any other
relevant U.S. Government agency.
The importation of Cuban-origin information and informational materials, as defined in section
515.332 of the CACR, is exempt from the prohibitions in the CACR.

Links:

OFAC Notice

OFAC Cuba Travel Guidance

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51. Are Cuban nationals located outside of Cuba still considered blocked?

Yes, but any individual Cuban national who can establish that he or she has taken up permanent
residence outside of Cuba and otherwise meets the requirements set forth in 31 CFR § 515.505 is
generally licensed as an unblocked national.

52. Can U.S.-owned or -controlled entities in third countries engage in trade/commerce with
Cuban nationals located outside of Cuba?

U.S.-owned or -controlled entities in third countries may provide goods and services to a Cuban
national who is an individual located outside of Cuba, provided that the transaction does not
involve a commercial exportation, directly or indirectly, of goods or services to or from Cuba.
For a complete description of what this general license authorizes and the restrictions that apply,
please see 31 CFR § 515.585.

53. Are U.S.-owned or -controlled entities in third countries authorized to provide financial
services to Cuban nationals located outside of Cuba?

U.S.-owned or -controlled entities in third countries may provide financial services to a Cuban
national who is an individual located outside of Cuba, provided that the transaction does not
involve a commercial exportation, directly or indirectly, of goods or services to or from Cuba. For a complete description of what this general license authorizes and the restrictions that apply,
please see 31 CFR § 515.585.

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On Wednesday, OFAC releases its Asset Terrorist Report for calendar year 2014. Amazingly enough, the amount of blocked assets decreased, year over year – due to a large drop in the funds blocked for Al-Qaida.

Funds blocked by countries designated as state sponsors of terrorism increased slightly (about 1.5%).

Fun bedtime reading!

Links:

OFAC Notice

2014 Terrorist Asset Report

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54. What change has been made to the regulatory interpretation of “cash in advance”?

The regulatory interpretation of “cash in advance” has been changed from “cash before shipment”
to “cash before transfer of title and control” to allow expanded financing options for authorized
exports to Cuba. For the full text, see 31 CFR § 515.533.

55. What types of projects would fall within the authorization in 31 CFR § 515.575 for
microfinancing projects?

Among other things, the provision for microfinancing projects in Section 515.575 of the CACR
authorizes the provision of certain financial services to unemployed, underemployed, and low-
income Cubans who have little or no access to conventional banks or comparable resources, and
which may include a limited return on investment. In addition, Section 515.570(g)(1) of the
CACR authorizes remittances to individuals and independent non-governmental entities in Cuba
to support authorized microfinancing projects. These provisions would authorize, for example,
relatively limited contributions of funds to support individual entrepreneurs in sectors that need
access to working capital, investment loans, insurance, or training in order to start or expand their
operations. Sections 515.575 and 515.570(g)(1) of the CACR do not authorize loans, extensions
of credit or other financing related to transactions involving confiscated property the claim to
which is owned by a U.S. national, which are prohibited by 31 CFR § 515.208. For additional
guidance or fact-specific questions, we would encourage you to contact OFAC.

56. If a person had applied for a specific license from OFAC before the CACR was revised but
now believes that the proposed activity is authorized pursuant to a general license, does that
person need to wait for his or her specific license application to be adjudicated?

No. If persons meet the qualifications listed in the general license, then they do not need to wait
for an official determination from OFAC regarding their specific license application. Persons
who have determined they may proceed under a general license may wish to contact OFAC
Licensing to withdraw existing applications.

57. What types of goods and services produced by independent Cuban entrepreneurs are
authorized for importation into the United States from Cuba pursuant to 31 CFR §
515.582?

Pursuant to Section 515.582 of the CACR, certain goods and services produced by independent Cuban entrepreneurs, as set forth in a list maintained by the State Department on its website, are authorized for importation, and persons subject to U.S. jurisdiction may engage in associated transactions necessary to import these authorized goods and services. The State Department list provides details of the goods and services authorized for importation into the U.S. from Cuba pursuant to this provision. This list references sections and chapters of the Harmonized Tariff Schedule (HTS) of the United States to indicate categories of goods that are not eligible for importation into the United States pursuant to 31 CFR §515.582, even if such goods were produced by independent Cuban entrepreneurs; any other goods produced by independent Cuban entrepreneurs and not covered by the listed sections and chapters of the HTS may be imported, as provided in the State Department’s Section 515.582 List and subject to compliance with all other

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On May 6th, Her Majesty's Treasury (HMT) renewed the Final Designation of:

1. KHALED, Mohammed, Fawaz
DOB: (1) 06/06/1969.

(2) 06/06/1967.
POB: Hama, Syria

a.k.a: (1) ABBAS, Adam, Del, Toro
(2) ALHARETH, Abo

(3) FAWAZ, Khaled

(4) HAMAWI, Abu

(5) HAMWI, Abu

(6) HARES, Abu

(7) HARETH, Abu

(8) KHALED, Abu

(9) NAEEM, Mohammed, Fawaz

Nationality: Syrian

Passport Details: 2255278 (Syria)

Address: London, United Kingdom, W12.

Other Information: UK listing only.

Listed on: 09/05/2013 Last Updated: 06/05/2015
Group ID: 12872.

for another year under the authority of the Terrorist Asset-Freezing etc Act 2010 (TAFA).

Link:

HMT Notice

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In line with Commission Implementing Regulation (EU) No 2015/769, Her Majesty’s Treasury (HMT) today removed the following 6 individuals:

AL-JELASSI, Riadh, Ben Belkassem, Ben Mohamed

DOB: 15/12/1970. POB: Al-Mohamedia, Tunisia Nationality: Tunisian Passport Details:
L276046 (Tunisian). Issued on 1 July 1996. Expired on 30 June 2001 Other Information:
UN Ref QI.A.71.02. Mother’s name is Reem Al-Askari. Member of Tunisian Combatant
Group. Listed on: 05/09/2002 Last Updated: 14/05/2015 Group ID: 7214.

AL-JENDOUBI, Faouzi, Ben Mohamed, Ben Ahmed

DOB: 30/01/1966. POB: (1) Tunis (2) -, (1) Tunisia (2) Morocco a.k.a: FAOUZI,
Jendoubi Nationality: Tunisian Passport Details: K459698 (Tunisian). Issued on 6 Mar
1999, expired on 5 Mar 2004 Other Information: UN Ref QI.A.101.03. Also referred to
as Said and Samir. Mother’s name is Um Hani al-Tujani. Inadmissible to the Schengen
area. Reported untraceable by the Italian authorities since June 2002. Listed on:
27/06/2003 Last Updated: 14/05/2015 Group ID: 7802.

AL-TLILI, Al-Azhar, Ben Mohammed, Ben El-Abed

DOB: 26/03/1969. POB: Feriana, Al-Kasrain, Tunisia a.k.a: TLILI, Lazar, Ben
Mohammed Nationality: Tunisian Passport Details: M 351140 (Tunisian). Expired on 16
June 2005 National Identification no: Italian Fiscal Code

TLLLHR69C26Z352G Address: Via Carlo Porta n.97, Legnano, Italy. Other Information:
UN Ref QI.A.77.02. Extradited from France to Italy on 6 Sept 2006. Released from
prison in Italy on 15 Jan 2007. Sentenced in absentia in Tunisia to 20 years of
imprisonment. Mother’s name is Essayda Bint Salih Al-Tlili. Listed on: 05/09/2002 Last
Updated: 14/05/2015 Group ID: 7515.

AL-WAZ, Najib, Ben Mohamed, Ben Salem

DOB: 12/04/1960. POB: Al Haka’imah, Governorate of Mahdia, Tunisia

a.k.a: (1) NAGIB, Ouaz (2) NAJIB, Ouaz Nationality: Tunisian Passport Details:
K815205 (Tunisian). Issued on 17 Sept 1994, expired on 16 Sept 1999 Address: Via
Tovaglie no 26, Bologna, Italy. Other Information: UN Ref QI.A.104.03. Mother’s name
is Salihah Amir. Inadmissible to the Schengen area. Listed on: 27/06/2003 Last Updated:
14/05/2015 Group ID: 7804.

KISHK, Samirm, Abd El Latif, El Sayed

DOB: 14/05/1955. POB: Gharbia, Egypt a.k.a: KESHK, Samir, Abdellatif, el

Sayed Nationality: Egyptian Other Information: UN Ref QI.K.73.02. Deported from Italy
to Egypt on 2 July 2003 Listed on: 05/09/2002 Last Updated: 14/05/2015 Group ID:
7228.

RARRBO, Ahmed, Hosni

DOB: 12/09/1974. POB: (1) Bologhine, (1) Algeria (2) France a.k.a: (1) ABDALLAH,
Rarrbo (2) ABDULLAH, Rarrbo (3) HOSNI, Rarrbo, Ahmed Nationality:

Algerian Address: Algeria. Other Information: UN Ref QI.R.103.03. Listed on:
27/06/2003 Last Updated: 14/05/2015 Group ID: 7806.

from their Consolidated List, where they were designated under the Al-Qaida sanctions program.

Links:

HMT Notice

Commission Implementing Regulation (EU) No 2015/769

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On May 7th, OFAC updated 2 FAQs related to Ukraine-related sanctions (395 and 419) and added a new question (453). Here they are:

FAQ 395:

395. Do Directives 1, 2, and 3 prohibit U.S. persons from dealing in or processing transactions under a letter of credit that was issued on or after the sanctions effective date and that carries a term of longer than 30 days maturity (for Directives 1 and 3) or 90 days maturity (for Directive 2) when the beneficiary or the issuing bank of that letter of credit is one of the entities identified as subject to the Directives?

U.S. persons may deal in (including act as the advising or confirming bank or as the applicant (i.e., the purchaser of the underlying goods or services)) or process transactions under a letter of credit in which an entity subject to Directive 1, 2, or 3 is the beneficiary (i.e., the exporter or seller of the underlying goods or services) because the subject letter of credit does not represent an extension of credit to the SSI entity. U.S. persons may deal in (including act as the advising or confirming bank or as the applicant or beneficiary) or process transactions under a letter of credit where the issuing bank is an SSI entity provided that the terms of all payment obligations under the letter of credit conform with the debt prohibitions under the applicable Directives. For example, a U.S. bank acting as the negotiating bank for a letter of credit issued by an SSI entity subject to Directive 1 should ensure that it receives reimbursement from the SSI entity within the allowable 30-day debt limit.

U.S. persons may not deal in (including act as the advising or confirming bank or as the beneficiary) or process transactions under a letter of credit if all of the following three conditions are met: (1) the letter of credit was issued on or after the sanctions effective date, (2) the letter of credit carries a term of longer than 30 days maturity (for persons subject to Directives 1 and 3) or 90 days maturity (for persons subject to Directive 2), and (3) an SSI entity is the applicant of the letter of credit. This would constitute prohibited activity because the subject letter of credit would represent an extension of credit to the SSI entity. [5-7-2015]

FAQ 419:

419. How should U.S. persons account for the 30- and 90-day debt prohibitions under Directives 1, 2, and 3 as they relate to payment terms for the following types of transactions: (1) the sale of goods to an SSI entity, (2) the provision of services to and subscription arrangements involving SSI entities, and (3) progress payments for long-term projects?

U.S. persons may engage in commercial transactions with SSI entities provided that any such transactions do not represent a direct or indirect dealing in prohibited debt or equity. Because offering payment terms of longer than 30 or 90 days to an SSI entity generally constitutes a prohibited dealing in debt of the SSI entity, U.S. persons should ensure that payment terms conform with the applicable debt prohibitions. For sales of goods to an SSI entity, U.S. persons may extend payment terms of up to 30 or 90 days from the point at which title or ownership of the goods transfers to the SSI entity. For the provision of services to, subscription arrangements involving, and progress payments for long-term projects involving SSI entities, U.S. persons may extend payment terms of up to 30 or 90 days from the point at which a final invoice (or each final invoice) is issued. Payments made under these types of payment terms should utilize a value date of not later than 30 or 90 days from either the point at which title or ownership has transferred (for payments relating to sales of goods) or the date of each final invoice (for payments relating to services, subscription arrangements, and progress payments). In the event that a U.S. person believes that it may not receive payment in full by the end of the 30- or 90-day period, the U.S. person should contact OFAC to determine whether a license or other authorization is required. [5-7-2015]

FAQ 453:

453. Pursuant to General License 6 under the Ukraine-Related Sanctions Program, are U.S. financial institutions authorized to process noncommercial, personal remittances to or from Crimea (or to or from individuals ordinarily resident in Crimea) when there is no individual who is a U.S. person as either the remitter or beneficiary in the transaction?

Yes. U.S. depository institutions, U.S.-registered brokers or dealers in securities, and U.S.-registered money transmitters are authorized to process noncommercial, personal remittances pursuant to General License 6 regardless of whether the originator or beneficiary is an individual who is a U.S. person. For example, General License 6 authorizes a U.S. depository institution to act as the intermediary financial institution and sole U.S. party in a payment representing a personal remittance originated by a non-U.S. person located outside of the United States for the benefit of an individual located in or ordinarily resident in Crimea. [5-7-2015]

Links:

OFAC Notice

FAQ 395

FAQ 419

FAQ 453

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On May 8th, Swiss regulators changed the following Al-Qaida sanctions listing:

SSID: 10-17254 Foreign identifier: QE.A.71.02. Name: Al-Haramain Islamic Foundation
Good quality a.k.a.: a) Vazir b) Vezir Address: a) 64 Poturmahala, Travnik, Bosnia and
Herzegovina b) Sarajevo, Bosnia and Herzegovina

Relation: Employees and associates include Najib Ben Mohamed Ben Salem Al-Waz
(QI.A.104.03., SSID 10-14753) Other information: Under criminal investigation by the
authorities of Bosnia and Herzegovina as of Nov 2007. Employees and associates include
Najib Ben Mohamed Ben Salem Al-Waz (listed under permanent reference number
QI.A.104.03.). Review pursuant to Security Council resolution 1822 (2008) was concluded
on 22 Jun 2010. Modifications: Amended on 8 May 2015

and de-listed the following 6 individuals:

SSID: 10-14346 Foreign identifier: QI.A.71.02. Name: Riadh Ben Belkassem Ben
Mohamed Al-Jelassi

DOB: 15 Dec 1970 POB: Al-Mohamedi, Tunisia Address: Italy Nationality: Tunisia
Identification document: Passport No. L276046, Tunisia, Date of issue: 1 Jul 1996, Expiry
date: 30 Jun 2001

Relation: Member of Tunisian Combatant Group (QE.T.90.02., SSID 10-17799) Other
information: Mother’s name is Reem Al-Askari. Member of Tunisian Combatant Group
(QE.T.90.02). Review pursuant to Security Council resolution 1822 (2008) was concluded on
21 Apr 2010. Modifications: De-listed on 8 May 2015

SSID: 10-14356 Foreign identifier: QI.A.101.03. Name: Faouzi Ben Mohamed Ben Ahmed
Al-Jendoubi

DOB: 30 Jan 1966 POB: a) Tunis, Tunisia b) Morocco Good quality a.k.a.: Jendoubi Faouzi Low quality a.k.a.: a) Said b) Samir Nationality: Tunisia Identification document:
Passport No. K459698, Tunisia, Date of issue: 6 Mar 1999, Expiry date: 5 Mar 2004

Other information: Mother’s name is Um Hani al-Tujani. Inadmissible to the Schengen
area. Reported untraceable by the Italian authorities since June 2002. Review pursuant to
Security Council resolution 1822 (2008) was concluded on 22 Apr 2010. Modifications: De-
listed on 8 May 2015

SSID: 10-14642 Foreign identifier: QI.A.77.02. Name: Al-Azhar Ben Mohammed Ben El-
Abed Al-Tlili

DOB: 26 Mar 1969 POB: Feriana, Al-Kasrain, Tunisia Good quality a.k.a.: Lazar Ben
Mohammed Tlili Address: Via Carlo Porta n. 97, Legnano, Italy Nationality: Tunisia
Identification document: Passport No. M 351140, Tunisia, Expiry date: 16 Jun 2005
Other information: Italian Fiscal Code: TLLLHR69C26Z352G. Extradited from France to
Italy on 6 Sep 2006. Released from prison in Italy on 15 Jan 2007. Sentenced in absentia in
Tunisia to twenty years of imprisonment. Mother’s name is Essayda Bint Salih Al-Tlili.
Review pursuant to Security Council resolution 1822 (2008) was concluded on 21 Apr 2010.
Modifications: De-listed on 8 May 2015

SSID: 10-14753 Foreign identifier: QI.A.104.03. Name: Najib Ben Mohamed Ben Salem
Al-Waz

DOB: 12 Apr 1960 POB: Al Haka’imah, Governorate of Mahdia, Tunisia Good quality
a.k.a.: a) Ouaz Najib b) Ouaz Nagib Address: Via Tovaglie Number 26, Bologna, Italy
Nationality: Tunisia Identification document: Passport No. K815205, Tunisia, Date of
issue: 17 Sep 1994, Expiry date: 16 Sep 1999

Other information: Mother’s name is Salihah Amir. Inadmissible to the Schengen area.
Review pursuant to Security Council resolution 1822 (2008) was concluded on 22 Apr 2010.
Modifications: De-listed on 8 May 2015

SSID: 10-16084 Foreign identifier: QI.K.73.02. Name: Samir Abd El Latif El Sayed Kishk
DOB: 14 May 1955 POB: Gharbia, Egypt Good quality a.k.a.: Samir Abdellatif el Sayed
Keshk Nationality: Egypt

Other information: Deported from Italy to Egypt on 2 July 2003. Review pursuant to
Security Council resolution 1822 (2008) was concluded on 16 Jul 2010. Modifications: De-
listed on 8 May 2015

SSID: 10-16557 Foreign identifier: QI.R.103.03. Name: Ahmed Hosni Rarrbo

DOB: 12 Sep 1974 POB: a) Bologhine, Algeria b) France Good quality a.k.a.: a) Rarrbo
Abdallah b) Rarrbo Abdullah c) Rarrbo Ahmed Hosni Address: Algeria Nationality: Algeria
Other information: Review pursuant to Security Council resolution 1822 (2008) was
concluded on 15 Jun 2010. Modifications: De-listed on 8 May 2015

Links:

FINMA Notice

Data files of updates – PDF, XML

Posted with Blogsy

On Friday, Her Majesty's Treasury announced changes to EU sanctions for South Sudan and the Central African Republic. For South Sudan, the EU is repealing the current sanctions regulations, and replacing them with new regulations that merge the current ones with the recent imposition of sanctions by the UN Security Council – which requires an update to the UK's statute since there is a new, rather than amended, EU regulation. For the Central African Republic, no UK change is necessary, as the EU amended an existing regulation. As the press release notes, no sanctions listings have changed due to these changes.

The press release from HMT reads:

South Sudan

In 2014 the European Union imposed restrictive measures, including an asset freeze, on certain persons involved in obstructing the political process in South Sudan or committing serious human rights violations. These measures were imposed by Council Regulation (EU) No 224/2014.

This regulation has since been repealed by Council Regulation (EU) 2015/735 on 7 May 2015 in order to integrate the United Nations Security Council Resolution (UNSCR) 2206 (2015) with the EU regulation. To note, the asset freeze, on certain persons involved in obstructing the political process in South Sudan or committing serious human rights violations still remain and those listed have not changed.

The UK Statutory Instrument will be updated in due course.

For more information, please follow this link:

https://www.gov.uk/government/publications/financial-sanctions-south-sudan

Central African Republic

On 10 March 2014 the Council of the European Union adopted Council Regulation (EU) 224/2014 (“the Regulation”), which imposes financial sanctions, including asset freezes, against individuals, entities and bodies in view of the situation in the Central African Republic. On 7 Mary 2015, Council Regulation (EU) No 224/2014 was amended by Council Regulation (EU) No 2015/734. Please note, the listings for this regime remain unchanged.

For more information, please follow this link:

https://www.gov.uk/government/publications/financial-sanctions-central-african-republic

Posted with Blogsy

On May 12th, Swiss regulators added the following person:

SSID: 80-30550 Name: Golparvar Gholam Hossein

DOB: 23 Jan 1957 Nationality: Iran Identification document: ID card No. 4207, Iran
Justification: Mr Golparvar acts on behalf of IRISL and companies associated with it. He
has been commercial director of IRISL, as well as Managing Director and shareholder of the
SAPID Shipping Company, non-executive director and shareholder of HDSL, and
shareholder of Rhabaran Omid Darya Ship Management Company, which are designated by
the EU as acting on behalf of IRISL. Relation: Acts on behalf of Islamic Republic of Iran
Shipping Lines (IRISL) (113., SSID 80-9702) Modifications: Listed on 12 May 2015

to its Consolidated List under its sanctions against Iran. It delisted the following 7 entities:

SSID: 80-10243 Foreign identifier: 203. Name: Kerman Shipping Company Ltd
Address: 143/1 Tower Road, Sliema, SLM1604, Malta

Justification: Kerman Shipping Company Ltd is a wholly-owned subsidiary of IRISL.
Located at the same address in Malta as Woking Shipping Investments Ltd and the
companies it owns. Relation: Subsidiary of Islamic Republic of Iran Shipping Lines (IRISL)
(113., SSID 80-9702) Other information: C37423, Incorporated in Malta in 2005; IMO
number: 9209350. Modifications: De-listed on 12 May 2015

SSID: 80-10293 Foreign identifier: 211. Name: Lancelin Shipping Company Ltd

Address: Fortuna Court, Block B, 284 Archiepiskopou Makariou C’ Avenue, 2nd Floor,
Limassol, 3105, Cyprus

Justification: Lancelin Shipping Company Ltd is wholly-owned by IRISL. Ahmad Sarkandi is
the manager of Lancelin Shipping. Relation: Owned by Islamic Republic of Iran Shipping
Lines (IRISL) (113., SSID 80-9702) Other information: Business Registration #C133993
(Cyprus), issued 2002; IMO number: 9213387. Modifications: De-listed on 12 May 2015

SSID: 80-10939 Foreign identifier: 283. Name: Woking Shipping Investments Ltd
Address: 143/1 Tower Road, Sliema, SLM1604, Malta

Justification: Woking Shipping Investments Ltd is an IRISL subsidiary that owns Shere
Shipping Company Limited, Tongham Shipping Co. Ltd., Uppercourt Shipping Company
Limited, Vobster Shipping Company which are all located at the same address in Malta.
Relation: a) Subsidiary of Islamic Republic of Iran Shipping Lines (IRISL) (113., SSID 80-
9702) b) Owner of Shere Shipping Company Limited (283.a, SSID 80-10945) c) Owner of
Tongham Shipping Co. Ltd (283.b, SSID 80-10951) d) Owner of Uppercourt Shipping
Company Limited (283.c, SSID 80-10957) e) Owner of Vobster Shipping Company (283.d,
SSID 80-10963) Other information: C39912 issued 2006. Modifications: De-listed on 12
May 2015

SSID: 80-10945 Foreign identifier: 283.a Name: Shere Shipping Company Limited
Address: 143/1 Tower Road, Sliema, SLM1604, Malta

Justification: Shere Shipping Company Limited is a wholly owned subsidiary of Woking
Shipping Investments Ltd, owned by IRISL. Relation: Subsidiary of Woking Shipping
Investments Ltd (283., SSID 80-10939) Other information: IMO number: 9305192.
Modifications: De-listed on 12 May 2015

SSID: 80-10951 Foreign identifier: 283.b Name: Tongham Shipping Co. Ltd

Address: 143/1 Tower Road, Sliema, SLM1604, Malta

Justification: Tongham Shipping Co. Ltd is a wholly owned subsidiary of Woking Shipping
Investments Ltd, owned by IRISL. Relation: Subsidiary of Woking Shipping Investments Ltd
(283., SSID 80-10939) Other information: IMO number: 9305219. Modifications: De-listed
on 12 May 2015

SSID: 80-10957 Foreign identifier: 283.c Name: Uppercourt Shipping Company Limited
Address: 143/1 Tower Road, Sliema, SLM1604, Malta

Justification: Uppercourt Shipping Company Limited is a wholly owned subsidiary of
Woking Shipping Investments Ltd, owned by IRISL. Relation: Subsidiary of Woking
Shipping Investments Ltd (283., SSID 80-10939) Other information: IMO number:
9305207. Modifications: De-listed on 12 May 2015

SSID: 80-10963 Foreign identifier: 283.d Name: Vobster Shipping Company

Address: 143/1 Tower Road, Sliema, SLM1604, Malta

Justification: Vobster Shipping Company is a wholly owned subsidiary of Woking Shipping
Investments Ltd, owned by IRISL. Relation: Subsidiary of Woking Shipping Investments Ltd
(283., SSID 80-10939) Other information: IMO number: 9305221. Modifications: De-listed
on 12 May 2015

and 3 individuals:

SSID: 80-13265 Foreign identifier: 42. Name: Heydari Nabiollah

Justification: Head of the Iranian Airport Police Authority. He has been instrumental, since
June 2009, in arresting at Imam Khomeini International Airport Iranian protesters who were
trying to leave the country after the crackdown started – including inside the international
zone. Modifications: De-listed on 12 May 2015

SSID: 80-13414 Foreign identifier: 70. Name: Rezvani Gholomani

Justification: Deputy Governor of Rasht. Responsible for grave violations of the right to due
process. Modifications: De-listed on 12 May 2015

SSID: 80-13422 Foreign identifier: 72. Name: Elahi Mousa Khalil

Justification: Prosecutor of Tabriz. Responsible for directing grave human rights violations
of the right to due process. Modifications: De-listed on 12 May 2015

It also updated the information for 33 entities, including Bank Tejarat and a number of cargo vessels and ship management companies, and 40 individuals.

Links:

FINMA Notice

Data files of updates: PDF, XML

Posted with Blogsy

On May 19, Australian and Canadian regulators delisted the following person:

QDi.234 Name: 1: ABDUL RAHIM 2: na 3: na 4: AL-TALHI

Name (original script): عبد الرحيم حماد أحمد الطلحي

Title: na Designation: na DOB: 8 Dec. 1961 POB: Al-Shefa, Al-Taif, Saudi Arabia Good quality a.k.a.: a) ‘Abdul-Rahim Hammad al-Talhi b) Abd’ Al-Rahim Hamad al-Tahi c) Abdulrheem Hammad A Altalhi d) Abe Al-Rahim al-Talahi e) Abd Al-Rahim Al Tahli f) ‘Abd al-Rahim al-Talhi g) Abdulrahim Al Tahi h) Abdulrahim al-Talji i)’Abd-Al-Rahim al Talji j) Abdul Rahim Hammad Ahmad Al-Talhi Low quality a.k.a.: a) Abdul Rahim b) Abu Al Bara’a Al Naji c) Shuwayb Junayd Nationality: Saudi Arabian Passport no.: Saudi Arabian passport number F275043, issued on 29 May 2004 (expired 5 Apr. 2009) National identification no.: na Address: Buraydah, Saudi Arabia Listed on: 9 Oct. 2007 (amended on 20 Feb. 2008, 13 Dec. 2011) Other information: Involved in the financing of, arms supply to and otherwise provided assistance to the Abu Sayyaf Group (QDe.001). Review pursuant to Security Council resolution 1822 (2008) was concluded on 14 Sep. 2009.

after their removal from the United Nations' Al-Qaida sanctions list.

Links:

OSFI Notice

UN Notice – HTML (OSFI), PDF (DFAT)

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Today, OFAC updated the Iran, counter-terrorism and counter-narcotics trafficking sanctions programs. They added the following 6 persons to the SDN List – all but the last under the Kingpin Act (last one is under the Iran – IFSR and terror programs):

BEATTIE DE BRIONES, Myriam Susana (a.k.a. BEATTIE BRIONES, Myriam Susana; a.k.a. BEATTIE MARTINEZ, Myriam Susana), Calle Segunda y Canales No. 10, Zona Centro, Matamoros, Tamaulipas, Mexico; DOB 17 Oct 1978; POB Monterrey, Nuevo Leon, Mexico; R.F.C. BESM781017MY2 (Mexico); alt. R.F.C. BESM781017HV1 (Mexico); alt. R.F.C. BESM781017162 (Mexico); C.U.R.P. BEMM781017MNLTRY05 (Mexico); I.F.E. 0539041296164 (Mexico) (individual) [SDNTK].

BRIONES RUIZ, Abel, Calle Bustamante No. 187, Matamoros, Tamaulipas, Mexico; DOB 31 Oct 1973; POB Matamoros, Tamaulipas, Mexico; R.F.C. BIRA731031BU4 (Mexico); C.U.R.P. BIRA731031HTSRZB03 (Mexico); I.F.E. 05116040222575 (Mexico) (individual) [SDNTK].

BRIONES RUIZ, Claudia Aide, Calle Bustamante 19 y 20, No. 187, Zona Centro, Matamoros, Tamaulipas 87300, Mexico; DOB 01 Oct 1981; POB Matamoros, Tamaulipas, Mexico; R.F.C. BIRC811001A56 (Mexico); C.U.R.P. BIRC811001MTSRZL05 (Mexico); I.F.E. 0516041106955 (Mexico) (individual) [SDNTK].

NIETO GONZALEZ, Rogelio; DOB 13 Mar 1978; POB Matamoros, Tamaulipas, Mexico; R.F.C. NIGR780313JK2 (Mexico); C.U.R.P. NIGR780313HTSTNG02 (Mexico) (individual) [SDNTK].

RUIZ DE BRIONES, Magdalena (a.k.a. RUIZ CARRION, Magdalena); DOB 01 Jul 1950; POB Matamoros, Tamaulipas, Mexico; R.F.C. RUBM50070167A (Mexico); alt. R.F.C. RUCM500701513 (Mexico); C.U.R.P. RUCM500701MTSZRG01 (Mexico) (individual) [SDNTK].

SHAMMOUT, Issam (a.k.a. SHAMMOUT, Muhammad Isam Muhammad Anwar Nur); DOB 26 Aug 1971; Additional Sanctions Information – Subject to Secondary Sanctions; Passport 006327129 (Syria) (individual) [SDGT] [IFSR] (Linked To: MAHAN AIR).

and 3 entities – first and last under terror and Iran sanctions, middle one under narcotics trafficking sanctions:

AL-NASER AIRLINES (a.k.a. ALNASER AIRLINES), Al-Karrada, Babil Region – District 929, St. 21, Home 46, Baghdad, Iraq; P.O. Box 28360, Dubai, United Arab Emirates; P.O. Box 911399, Amman 11191, Jordan; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: MAHAN AIR).

COMBUSTIBLES BRIONES, S.A. DE C.V., Carr. a Reynosa Km 21, Tamaulipas, Mexico [SDNTK].

SKY BLUE BIRD AVIATION (a.k.a. SKY BLUE AIRLINES; a.k.a. SKY BLUE BIRD FZE), P.O. Box 16111, Ras al Khaimah Trade Zone, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: MAHAN AIR).

and these 9 aircraft, all under the Iran and terrorism programs:

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

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

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

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

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

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

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

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

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

Link:

OFAC Notice

Posted with Blogsy

On May 13th, Swiss regulators modified the listings for the following 4 persons listed under their Libya sanctions program:

SSID: 130-12905 Name: Al-Barassi Safia Farkash

DOB: 1952 POB: Al Bayda, Libya Good quality a.k.a.: Safia Farkash Mohammed Al-Hadad
Address: Oman (Believed status/location: Sultanate of Oman) Identification document:
Passport No. 03825239, Oman (born 1 Jan 1953)

Justification: Married to Muammar Qadhafi since 1970. Significant personal wealth, which
could be used for regime purposes. Her sister Fatima Farkash is married to Abdallah
Sanussi, head of Libyan military intelligence. Relation: Wife of Qadhafi Muammar
Mohammed Abu Minyar (SSID 130-12812) Other information: Believed status/location:
Algeria. Modifications: Amended on 22 Mar 2013, 13 May 2015

SSID: 130-12916 Name: Al-Baghdadi Abdulqader Mohammed

Title: Dr DOB: 1 Jul 1950 Address: Tunisia (Believed status/location: jail in Tunisia)
Identification document: Passport No. B010574, Libya

Justification: Head of the Liaison Office of the Revolutionary Committees. Revolutionary
Committees involved in violence against demonstrators. Other information: Believed
status/location: jail in Tunisiadeceased Modifications: Amended on 13 May 2015

SSID: 130-13001 Name: Qadhafi Saadi

DOB: a) 27 May 1973 b) 1 Jan 1975 POB: Tripoli, Libya Address: Libya (in custody)
Identification document: a) Passport No. 014797, Libya b) Passport No. 524521, Libya
Justification: Commander Special Forces. Son of Muammar Qadhafi. Closeness of
association with regime. Command of military units involved in repression of demonstrations
Other information: Believed status/location: Niger. Modifications: Amended on 13 May
2015

SSID: 130-21080 Name: Al Qadhafi Quren Salih Quren

Good quality a.k.a.: Akrin Saleh Akrin Address: Egypt

Justification: Libyan Ambassador to Chad. Has left Chad for Sabha. Involved directly in
recruiting and coordinating mercenaries for the regime. Modifications: Amended on 13 May
2015

The first and 3rd are subject to financial sanctions – all 4 are subject to travel restrictions.

Links:

FINMA Notice

Data files of updates – PDF, XML

Posted with Blogsy

On Wednesday, British regulators implemented Council Implementing Regulation (EU) No 2015/780 by adding a listing for the following entity:

TRI-OCEAN ENERGY

Address: 35b Saray El Maadi Tower, Corniche El Nile, Maadi, Cairo, PO Box 1313,
Egypt, 11431. Other Information: Organises covert shipments of oil to the Syrian
regime. Listed on: 20/05/2015 Last Updated: 20/05/2015 Group ID: 13251.

and modifying the listings for the following 4 individuals:

ABDULKARIM, Wael

a.k.a: AL KARIM, Wael Position: Managing Director of Pangates International Corp Ltd
and also holds a senior position in the Al Karim Group, which is Pangates’ parent
company. Address: (1) Al Karim for Trade and Industry, PO Box 111, Damascus, Syria,
5797. (2) Morgan Additives Office no 2206, 22nd floor, Jafza View 19, Besides Jafza
View 18, Sheikh Zayed Road, Jebel Ali Free Zone Authority, Dubai , UAE. (3) Pangates
International Corp Ltd, PO Box Sharjah Airport International Free zone, United Arab
Emirates. Other Information: Managing Director of the PANGATES INTERNATIONAL
CORP LTD and also holds a senior position in AL KARIM GROUP, which is PANGATES’
parent company. Listed on: 09/03/2015 Last Updated: 20/05/2015 Group ID: 13230.

ARMANAZI, Amr

DOB: 07/02/1944. a.k.a: (1) AL-ARMANAZI, Amr, Muhammad, Najib (2) AL-
ARMANAZY, Amrou (3) ARMANAZI, Amr, Najib Position: Director General of the
designated entity, the Syrian Scientific Studies and Research Centre (SSRC). Listed on:
23/07/2014 Last Updated: 20/05/2015 Group ID: 13024.

BARQAWI, Ahmad

a.k.a: BARQAWI, Ahmed Position: General Manager of Pangates International Corp Ltd
and manager of Al Karim Group. Address: (1) Al Karim for Trade and Industry, PO Box
111, Damascus, Syria, 5797. (2) Morgan Additives Office No 2206, 22nd floor, Jafaza
View 19, Besdides Jafza View 18, Sheikh Zayed Road, Jebel Ali Free Zone Authority,
Dubai, UAE. (3) Pangates International Corp Ltd, PO Box Sharjah Airport International Free Zone, United Arab Emirates. Other Information: General Manager of Pangates
International Corp Ltd. Manager of Al Karim Group. Listed on: 09/03/2015 Last
Updated: 20/05/2015 Group ID: 13231.

HAMSHO, Samir
DOB: 01/03/1972 a.k.a: (1) HAMCHO, Samir (2) HAMCHU, Samir (3) HAMISHO, Samir
(4) HEMASHO, Samir (5) HMEISHO, Samir (6) HMICHO, Samir (7) HMISHO, Samir
Address: (1) Hamsho Building, 31 Baghdad Street, Damascus, Syria. (2) 16 Martello
Road, Poole, BH13 7 DH, United Kingdom. (3). 290 Qura Al Assad, Damascus,
Syria. Position: Owner and chairman of Al Buroj and Syria Steel/Hmisho Steel. Passport
Details: (1) N008803455 (Syrian), (2) YA056959 (Brazilian). Other Information: Also
known as Samer or Sameer. Prominent Syrian businessman. Owner and chairman of Al
Buroj and Syria Steel/Hmisho Steel are subsidiaries of Hamsho Trading, a subsidiary of
Hamsho International. HMISHO, HAMCHU, HAMCHO, HAMISHO, HMEISHO and
HEMASHO. Listed on: 09/03/2015 Last Updated: 20/05/2015 Group ID: 13234.

and 2 entities:

CENTRE D’ETUDES ET DE RECHERCHES SYRIEN (CERS)

a.k.a: (1) Centre de Recherche de Kaboun (2) Centre d’Etude et de Recherche
Scientifique (CERS) (3) Scientific Studies and Research Center (SSRC) Address: Barzeh
Street, PO Box 4470, Damas. Other Information: Government entity responsible for
developing and producing non-conventional weapons, including chemical weapons, and
the missiles to deliver them. Listed on: 02/12/2011 Last Updated: 20/05/2015 Group ID:
12426.

TRI OCEAN TRADING TRI-OCEAN TRADING

a.k.a: Tri-Ocean Energy Address: (1) George Town, Cayman Islands. (2) 35b Corniche
El Nile, Cairo, Egypt 35b Saray El Maadi Tower, Corniche El Nile, Cairo, P.O. Box: 1313
Maadi, Egypt, 11431. Other Information: Subsidiary of Tri-Ocean Energy. Organises
covert shipments of oil to the Syrian regime. Listed on: 23/07/2014 Last Updated:
20/05/2015 Group ID: 13027.

Links:

HMT Notice

Council Implementing Regulation (EU) No 2015/780

Posted with Blogsy

Finland released a summary of recent EU regulatory updates on the 5th, as well as a best practices paper for implementing restrictive measures. The links appear below.

The Ministry of Foreign Affairs can be reached here.

Links:

Regulatory Update

Financial sanctions

The Democratic Republic of the Congo

• Council Decision (CFSP) 2015/620
• Council Regulation (EU) 2015/613
• Council Implementing Regulation (EU) 2015/614

Ivory Coast

• Council Decision (CFSP) 2015/621
• Council Implementing Regulation (EU) 2015/615

Zimbabwe

• Council Regulation (EU) 2015/612

Al-Qaeda

• Commission Implementing Regulation (EU) 2015/617
• Commission Implementing Regulation (EU) 2015/576
• Commission Implementing Regulation (EU) 2015/532

Iran

• Council Decision (CFSP) 2015/555
• Council Implementing Regulation (EU) 2015/548
• Council Decision (CFSP) 2015/556
• Council Implementing Regulation (EU) 2015/549

Other terrorist sanctions

• Council Decision (CFSP) 2015/521
• Council Implementing Regulation (EU) 2015/513

Export and import restrictions

Myanmar (Burma)

• Council Decision (CFSP) 2015/666

Travel Restrictions

The Democratic Republic of the Congo

• Council Decision (CFSP) 2015/620

Ivory Coast

• Council Decision (CFSP) 2015/621

Al-Qaeda

• Commission Implementing Regulation (EU) 2015/617
• Commission Implementing Regulation (EU) 2015/576
• Commission Implementing Regulation (EU) 2015/532

Iran

• Council Decision (CFSP) 2015/555
• Council Implementing Regulation (EU) 2015/548

EU Best Practices for the effective implementation of restrictive measures (pdf)

* The release from the Ministry of Foreign Affair links to the Finnish version of all links and documents. I’ve changed all of them to the English equivalents.

Posted with Blogsy

Just before heading off to Memorial Day weekend BBQs, the Office of Foreign Assets Control (OFAC) added the following 6 Colombian citizens to its Kingpin Act sanctions:

BOLIVAR ZAPATA, Gustavo; DOB 23 Dec 1976; POB Pereira, Risaralda, Colombia; Cedula No. 18513577 (Colombia) (individual) [SDNTK].

BUSTAMANTE JARAMILLO, Luis Carlos; DOB 04 Mar 1967; POB Apartado, Antioquia, Colombia; Cedula No. 71976633 (Colombia) (individual) [SDNTK].

GUARIN LOAIZA, Jose Berley (a.k.a. “EL ILUSTRE”); DOB 13 Jun 1968; POB Tulua, Valle, Colombia; Cedula No. 16365933 (Colombia) (individual) [SDNTK].

MEDINA DIAZ, Herman De Jesus; DOB 23 Mar 1968; POB Mistrato, Risaralda, Colombia; Cedula No. 18560548 (Colombia) (individual) [SDNTK].

ROMERO RODRIGUEZ, Alexis; DOB 28 Jul 1970; POB Cali, Colombia; Cedula No. 16790481 (Colombia) (individual) [SDNTK].

VARELA VICTORIA, Walter; DOB 20 Jun 1963; POB Tulua, Valle, Colombia; Cedula No. 16358495 (Colombia) (individual) [SDNTK].

and 3 entities – 2 of them in Panama:

FREEZER AIR CONTRACTOR S.A., Panama City, Panama; RUC # 916848-1-518421[SDNTK].

MEGAYATES LTDA, Bosque, Sector San Isidro, Transversal 54 No. 24-280, Cartagena, Bolivar, Colombia; NIT # 806006215-8 (Colombia) [SDNTK].

QUALITY AUTOS S.A., Panama City, Panama; RUC # 1067593-1-551241 [SDNTK].

and removed the following 21 people and entities:

TIRADO ESCAMILLA, Telesforo Baltazar (a.k.a. TIRADO ESCAMILLA, Telesforo Baltasar; a.k.a. TIRADO MARTINEZ, Baltazar), c/o PRODUCTOS FARMACEUTICOS COLLINS, S.A. DE C.V., Zapopan, Jalisco, Mexico; Maya 3290, Guadalajara, Jalisco, Mexico; Rinconada Del Tulipan 3485, Guadalajara, Jalisco, Mexico; Calle Mallas 3278, Guadalajara, Jalisco, Mexico; DOB 10 Jan 1939; alt. DOB 09 Jan 1939; POB Nayarit, Mexico; nationality Mexico; citizen Mexico; C.U.R.P. TIET390110HNTRSL04 (Mexico) (individual) [SDNTK].

TIRADO ESCAMILLA, Telesforo Baltasar (a.k.a. TIRADO ESCAMILLA, Telesforo Baltazar; a.k.a. TIRADO MARTINEZ, Baltazar), c/o PRODUCTOS FARMACEUTICOS COLLINS, S.A. DE C.V., Zapopan, Jalisco, Mexico; Maya 3290, Guadalajara, Jalisco, Mexico; Rinconada Del Tulipan 3485, Guadalajara, Jalisco, Mexico; Calle Mallas 3278, Guadalajara, Jalisco, Mexico; DOB 10 Jan 1939; alt. DOB 09 Jan 1939; POB Nayarit, Mexico; nationality Mexico; citizen Mexico; C.U.R.P. TIET390110HNTRSL04 (Mexico) (individual) [SDNTK].

TIRADO MARTINEZ, Baltazar (a.k.a. TIRADO ESCAMILLA, Telesforo Baltasar; a.k.a. TIRADO ESCAMILLA, Telesforo Baltazar), c/o PRODUCTOS FARMACEUTICOS COLLINS, S.A. DE C.V., Zapopan, Jalisco, Mexico; Maya 3290, Guadalajara, Jalisco, Mexico; Rinconada Del Tulipan 3485, Guadalajara, Jalisco, Mexico; Calle Mallas 3278, Guadalajara, Jalisco, Mexico; DOB 10 Jan 1939; alt. DOB 09 Jan 1939; POB Nayarit, Mexico; nationality Mexico; citizen Mexico; C.U.R.P. TIET390110HNTRSL04 (Mexico) (individual) [SDNTK].

TIRADO DIAZ, Rolando, c/o PRODUCTOS FARMACEUTICOS COLLINS, S.A. DE C.V., Zapopan, Jalisco, Mexico; DOB 28 Mar 1971; POB Jalisco, Mexico; nationality Mexico; citizen Mexico; C.U.R.P. TIDR710328HJCRZL02 (Mexico) (individual) [SDNTK].

TIRADO DIAZ, Luis Alfonso, c/o PRODUCTOS FARMACEUTICOS COLLINS, S.A. DE C.V., Zapopan, Jalisco, Mexico; DOB 20 Jul 1968; POB Jalisco, Mexico; nationality Mexico; citizen Mexico; C.U.R.P. TIDL680720HJCRZS04 (Mexico) (individual) [SDNTK].

SALUD NATURAL MEXICANA, S.A. DE C.V., Alvaro Obregon 250, Colonia Agua Blanca, Zapopan, Jalisco 45235, Mexico; Avenida Inglaterra #3109, Guadalajara, Jalisco 44500, Mexico; R.F.C. SNM-950403-FA5 (Mexico) [SDNTK].

PRODUCTOS FARMACEUTICOS COLLINS, S.A. DE C.V. (a.k.a. GRUPO COLLINS; a.k.a. GRUPO FARMACEUTICO COLLINS; a.k.a. LABORATORIOS COLLINS), Avenida Lopez Mateos No. 1938, Colonia Agua Blanca, Zapopan, Jalisco 45070, Mexico; Pedro de Alacron No. 167, Zapopan, Jalisco, Mexico; Cipres No. 1677, Colonia Del Fresno, Guadalajara, Jalisco 44900, Mexico; Calle Vicente Guerrero 337, Colonia Agua Blanca, Zapopan, Jalisco 44008, Mexico; Prolongacion Lopez Mateos 1938, Colonia Agua Blanca, Zapopan, Jalisco 45070, Mexico; Calle Agua Prieta 1100, Colonia Agua Blanca, Zapopan, Jalisco 44008, Mexico; Puerto Soto La Marina 1632 A, Guadalajara, Jalisco 44330, Mexico; R.F.C. PFC8301273D1 (Mexico) [SDNTK].

GRUPO COLLINS (a.k.a. GRUPO FARMACEUTICO COLLINS; a.k.a. LABORATORIOS COLLINS; a.k.a. PRODUCTOS FARMACEUTICOS COLLINS, S.A. DE C.V.), Avenida Lopez Mateos No. 1938, Colonia Agua Blanca, Zapopan, Jalisco 45070, Mexico; Pedro de Alacron No. 167, Zapopan, Jalisco, Mexico; Cipres No. 1677, Colonia Del Fresno, Guadalajara, Jalisco 44900, Mexico; Calle Vicente Guerrero 337, Colonia Agua Blanca, Zapopan, Jalisco 44008, Mexico; Prolongacion Lopez Mateos 1938, Colonia Agua Blanca, Zapopan, Jalisco 45070, Mexico; Calle Agua Prieta 1100, Colonia Agua Blanca, Zapopan, Jalisco 44008, Mexico; Puerto Soto La Marina 1632 A, Guadalajara, Jalisco 44330, Mexico; R.F.C. PFC8301273D1 (Mexico) [SDNTK].

GRUPO FARMACEUTICO COLLINS (a.k.a. GRUPO COLLINS; a.k.a. LABORATORIOS COLLINS; a.k.a. PRODUCTOS FARMACEUTICOS COLLINS, S.A. DE C.V.), Avenida Lopez Mateos No. 1938, Colonia Agua Blanca, Zapopan, Jalisco 45070, Mexico; Pedro de Alacron No. 167, Zapopan, Jalisco, Mexico; Cipres No. 1677, Colonia Del Fresno, Guadalajara, Jalisco 44900, Mexico; Calle Vicente Guerrero 337, Colonia Agua Blanca, Zapopan, Jalisco 44008, Mexico; Prolongacion Lopez Mateos 1938, Colonia Agua Blanca, Zapopan, Jalisco 45070, Mexico; Calle Agua Prieta 1100, Colonia Agua Blanca, Zapopan, Jalisco 44008, Mexico; Puerto Soto La Marina 1632 A, Guadalajara, Jalisco 44330, Mexico; R.F.C. PFC8301273D1 (Mexico) [SDNTK].

LABORATORIOS COLLINS (a.k.a. GRUPO COLLINS; a.k.a. GRUPO FARMACEUTICO COLLINS; a.k.a. PRODUCTOS FARMACEUTICOS COLLINS, S.A. DE C.V.), Avenida Lopez Mateos No. 1938, Colonia Agua Blanca, Zapopan, Jalisco 45070, Mexico; Pedro de Alacron No. 167, Zapopan, Jalisco, Mexico; Cipres No. 1677, Colonia Del Fresno, Guadalajara, Jalisco 44900, Mexico; Calle Vicente Guerrero 337, Colonia Agua Blanca, Zapopan, Jalisco 44008, Mexico; Prolongacion Lopez Mateos 1938, Colonia Agua Blanca, Zapopan, Jalisco 45070, Mexico; Calle Agua Prieta 1100, Colonia Agua Blanca, Zapopan, Jalisco 44008, Mexico; Puerto Soto La Marina 1632 A, Guadalajara, Jalisco 44330, Mexico; R.F.C. PFC8301273D1 (Mexico) [SDNTK].

TIRADO DIAZ, Liliana Guadalupe, c/o ALIMENTOS SELECTOS SAN FRANCISCO S.P.R. DE R.L., Guadalajara, Jalisco, Mexico; DOB 23 Jul 1966; POB Mexico; nationality Mexico; citizen Mexico; C.U.R.P. TIDL660723MJCRZL07 (Mexico) (individual) [SDNTK].

TIRADO DIAZ, Baltazar, c/o ALIMENTOS SELECTOS SAN FRANCISCO S.P.R. DE R.L., Guadalajara, Jalisco, Mexico; c/o PRODUCTOS FARMACEUTICOS COLLINS, S.A. DE C.V., Zapopan, Jalisco, Mexico; DOB 27 Aug 1967; POB Mexico; nationality Mexico; citizen Mexico; C.U.R.P. TIDB670827HJCRZL07 (Mexico) (individual) [SDNTK].

TIRADO DIAZ, Maria Teresa, c/o ALIMENTOS SELECTOS SAN FRANCISCO S.P.R. DE R.L., Guadalajara, Jalisco, Mexico; Alvaro Obregon 250, Colonia Agua Blanca Sur, Zapopan, Jalisco 45235, Mexico; DOB 08 Dec 1976; POB Mexico; nationality Mexico; citizen Mexico; Electoral Registry No. TRDZTR76120814M700 (Mexico) issued 1997 (individual) [SDNTK].

DIAZ CASTRO, Maria Teresa (a.k.a. DIAZ DE TIRADO, Maria Teresa), c/o PRODUCTOS FARMACEUTICOS COLLINS, S.A. DE C.V., Zapopan, Jalisco, Mexico; c/o INSUMOS ECOLOGICOS DEL ORIENTE, S.A. DE C.V., Guadalajara, Jalisco, Mexico; DOB 23 Jan 1948; POB Sinaloa, Mexico; nationality Mexico; citizen Mexico; R.F.C. DICT480123I37 (Mexico); C.U.R.P. DICT480123MSLZSR05 (Mexico) (individual) [SDNTK].

DIAZ DE TIRADO, Maria Teresa (a.k.a. DIAZ CASTRO, Maria Teresa), c/o PRODUCTOS FARMACEUTICOS COLLINS, S.A. DE C.V., Zapopan, Jalisco, Mexico; c/o INSUMOS ECOLOGICOS DEL ORIENTE, S.A. DE C.V., Guadalajara, Jalisco, Mexico; DOB 23 Jan 1948; POB Sinaloa, Mexico; nationality Mexico; citizen Mexico; R.F.C. DICT480123I37 (Mexico); C.U.R.P. DICT480123MSLZSR05 (Mexico) (individual) [SDNTK].

ESPINOSA DE LOS MONTEROS RICO, Felipe De Jesus (a.k.a. ESPINOSA DE LOS RICO, Felipe de Jesus; a.k.a. ESPINOZA DE LOS MONTEROS, Felipe), c/o PRODUCTOS FARMACEUTICOS COLLINS, S.A. DE C.V., Zapopan, Jalisco, Mexico; c/o INSUMOS ECOLOGICOS DEL ORIENTE, S.A. DE C.V., Guadalajara, Jalisco, Mexico; c/o SALUD NATURAL MEXICANA, S.A. DE C.V., Zapopan, Jalisco, Mexico; Mexico; Avenida Naciones Unidas 5989, Cond. Ibiza Casa 34, Zapopan, Jalisco 45110, Mexico; DOB 15 Jun 1962; alt. DOB 15 Jan 1962; POB Mexico City; nationality Mexico; citizen Mexico; Passport 00140030868 (Mexico) (individual) [SDNTK].

ESPINOSA DE LOS RICO, Felipe de Jesus (a.k.a. ESPINOSA DE LOS MONTEROS RICO, Felipe De Jesus; a.k.a. ESPINOZA DE LOS MONTEROS, Felipe), c/o PRODUCTOS FARMACEUTICOS COLLINS, S.A. DE C.V., Zapopan, Jalisco, Mexico; c/o INSUMOS ECOLOGICOS DEL ORIENTE, S.A. DE C.V., Guadalajara, Jalisco, Mexico; c/o SALUD NATURAL MEXICANA, S.A. DE C.V., Zapopan, Jalisco, Mexico; Mexico; Avenida Naciones Unidas 5989, Cond. Ibiza Casa 34, Zapopan, Jalisco 45110, Mexico; DOB 15 Jun 1962; alt. DOB 15 Jan 1962; POB Mexico City; nationality Mexico; citizen Mexico; Passport 00140030868 (Mexico) (individual) [SDNTK].

ESPINOZA DE LOS MONTEROS, Felipe (a.k.a. ESPINOSA DE LOS MONTEROS RICO, Felipe De Jesus; a.k.a. ESPINOSA DE LOS RICO, Felipe de Jesus), c/o PRODUCTOS FARMACEUTICOS COLLINS, S.A. DE C.V., Zapopan, Jalisco, Mexico; c/o INSUMOS ECOLOGICOS DEL ORIENTE, S.A. DE C.V., Guadalajara, Jalisco, Mexico; c/o SALUD NATURAL MEXICANA, S.A. DE C.V., Zapopan, Jalisco, Mexico; Mexico; Avenida Naciones Unidas 5989, Cond. Ibiza Casa 34, Zapopan, Jalisco 45110, Mexico; DOB 15 Jun 1962; alt. DOB 15 Jan 1962; POB Mexico City; nationality Mexico; citizen Mexico; Passport 00140030868 (Mexico) (individual) [SDNTK].

BRAMBILA MARTINEZ, Aurora, c/o PRODUCTOS FARMACEUTICOS COLLINS, S.A. DE C.V., Zapopan, Jalisco, Mexico; c/o INSUMOS ECOLOGICOS DEL ORIENTE, S.A. DE C.V., Guadalajara, Jalisco, Mexico; c/o SALUD NATURAL MEXICANA, S.A. DE C.V., Zapopan, Jalisco, Mexico; Avenida Obregon 180, Colonia Puente Grande, Jalisco, Mexico; DOB 15 Dec 1965; POB Mexico; nationality Mexico; citizen Mexico; R.F.C. BAMA651215DI7 (Mexico); C.U.R.P. BAMA651215MJCRRR05 (Mexico); alt. C.U.R.P. BAMA651215MMCRRR04 (Mexico); Contadora Publica (individual) [SDNTK].

ALIMENTOS SELECTOS SAN FRANCISCO S.P.R. DE R.L., Chicharo 2680, Colonia Mercado de Abastos, Guadalajara, Jalisco 44530, Mexico; Rinconada de la Floresta 1243, Colonia Rinconada del Bosque, Guadalajara, Jalisco 44530, Mexico; R.F.C. ASS040427676 (Mexico) [SDNTK].

INSUMOS ECOLOGICOS DE ORIENTE, S.A. DE C.V., Jose I Solorzano 746, Colonia Jardines Alcalde, Guadalajara, Jalisco 44290, Mexico; R.F.C. IEO0806245A3 (Mexico) [SDNTK].

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