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May 17, 2016: Major changes to Burmese SDN Listings

May 20, 2016, 7:22 am
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On Tuesday, OFAC added a handful of entities linked to Stevem Law or Asia World Co Ltd: 

ASIA MEGA LINK CO., LTD., No. 39/40, Bogyoke Aung San Road, Bahosi Housing, Lanmadaw, Rangoon, Burma; Registration ID 1679/2009-2010 (Burma) [BURMA] (Linked To: ASIA WORLD CO. LTD.).
 
ASIA MEGA LINK SERVICES CO., LTD., No. 44/45, Bogyoke Aung San Road, Bahosi Housing Complex, Lanmadaw, Rangoon, Burma; Registration ID 2652/2010-2011 (Burma) [BURMA] (Linked To: ASIA WORLD CO. LTD.).
 
GLOBAL WORLD INSURANCE COMPANY LIMITED, No. 44, Thein Phyu Road, Corner of Bogyoke Aung San Road and Thein Phyu Road, Pazuntaung, Rangoon, Burma; Registration ID 2511/2012-2013 (Burma) [BURMA] (Linked To: ASIA WORLD CO. LTD.).
 
GREEN ASIA SERVICES CO. LTD., No. 61/62, Bahosi Housing, War Tan St., Lanmadaw T/S, Rangoon, Burma; Registration ID 4013/2011-2012 (Burma) [BURMA] (Linked To: ASIA WORLD CO. LTD.).
 
PIONEER AERODROME SERVICES CO., LTD., No. 203/204, Thiri Mingalar Housing, Strand Rd, Ahlone, Rangoon, Burma; Registration ID 620/2007-2008(Burma) [BURMA] (Linked To: ASIA WORLD CO. LTD.).
 
SHWE NAR WAH COMPANY LIMITED, No. 39/40, Bogyoke Aung San Road, Bahosi Housing, Lanmadaw, Rangoon, Burma; Registration ID 1922/2007-2008(Burma) [BURMA] (Linked To: LAW, Steven).

as well as removing a slew of other listings: 

MYANMA ECONOMIC BANK (a.k.a. MYANMAR ECONOMIC BANK), 1-19 Sule Pagoda Road, Pabedan T/S, Yangon, Burma [BURMA].
 
MYANMAR ECONOMIC BANK (a.k.a. MYANMA ECONOMIC BANK), 1-19 Sule Pagoda Road, Pabedan T/S, Yangon, Burma [BURMA].
 
MYANMA FOREIGN TRADE BANK (a.k.a. MYANMAR FOREIGN TRADE BANK), P.O. Box 203, 80-86 Maha Bandoola Garden Street, Kyauktada T/S, Yangon, Burma; SWIFT/BIC FOTMMMM1 [BURMA].
 
MYANMAR FOREIGN TRADE BANK (a.k.a. MYANMA FOREIGN TRADE BANK), P.O. Box 203, 80-86 Maha Bandoola Garden Street, Kyauktada T/S, Yangon, Burma; SWIFT/BIC FOTMMMM1 [BURMA].
 
MYANMA INVESTMENT AND COMMERCIAL BANK (a.k.a. MICB; a.k.a. MYANMAR INVESTMENT AND COMMERCIAL BANK), 170/176 Bo Aung Kyaw Street, Botataung Township, Yangon, Burma; SWIFT/BIC MYANMMM1; alt. SWIFT/BIC MICB MM MY; alt. SWIFT/BIC MICB MM MY MAN [BURMA].
 
MICB (a.k.a. MYANMA INVESTMENT AND COMMERCIAL BANK; a.k.a. MYANMAR INVESTMENT AND COMMERCIAL BANK), 170/176 Bo Aung Kyaw Street, Botataung Township, Yangon, Burma; SWIFT/BIC MYANMMM1; alt. SWIFT/BIC MICB MM MY; alt. SWIFT/BIC MICB MM MY MAN [BURMA].
 
MYANMAR INVESTMENT AND COMMERCIAL BANK (a.k.a. MICB; a.k.a. MYANMA INVESTMENT AND COMMERCIAL BANK), 170/176 Bo Aung Kyaw Street, Botataung Township, Yangon, Burma; SWIFT/BIC MYANMMM1; alt. SWIFT/BIC MICB MM MY; alt. SWIFT/BIC MICB MM MY MAN [BURMA].
 
CO-OPERATIVE EXPORT-IMPORT ENTERPRISE (a.k.a. CEIE), 259/263 Bogyoke Aung San Street, Yangon, Burma [BURMA].
 
CEIE (a.k.a. CO-OPERATIVE EXPORT-IMPORT ENTERPRISE), 259/263 Bogyoke Aung San Street, Yangon, Burma [BURMA].
 
MYANMAR GEM ENTERPRISE (a.k.a. MGE; a.k.a. MYANMA GEM ENTERPRISE), 66 Kaba Aye Pagoda Road, Rangoon, Mayangone Township (MYGN), Burma [BURMA].
 
MGE (a.k.a. MYANMA GEM ENTERPRISE; a.k.a. MYANMAR GEM ENTERPRISE), 66 Kaba Aye Pagoda Road, Rangoon, Mayangone Township (MYGN), Burma [BURMA].
 
MYANMA GEM ENTERPRISE (a.k.a. MGE; a.k.a. MYANMAR GEM ENTERPRISE), 66 Kaba Aye Pagoda Road, Rangoon, Mayangone Township (MYGN), Burma [BURMA].
 
MYANMAR TIMBER ENTERPRISE (a.k.a. MTE; a.k.a. MYANMA TIMBER ENTERPRISE), P.O. Box 206, Mission Road/Ahlone Street, Rangoon, Burma [BURMA].
 
MTE (a.k.a. MYANMA TIMBER ENTERPRISE; a.k.a. MYANMAR TIMBER ENTERPRISE), P.O. Box 206, Mission Road/Ahlone Street, Rangoon, Burma [BURMA].
 
MYANMA TIMBER ENTERPRISE (a.k.a. MTE; a.k.a. MYANMAR TIMBER ENTERPRISE), P.O. Box 206, Mission Road/Ahlone Street, Rangoon, Burma [BURMA].
 
MYANMAR PEARL ENTERPRISE (a.k.a. MPE; a.k.a. MYANMA PEARL ENTERPRISE), No. 4345, Bu Khwe, Naypyitaw, Burma [BURMA].
 
MPE (a.k.a. MYANMA PEARL ENTERPRISE; a.k.a. MYANMAR PEARL ENTERPRISE), No. 4345, Bu Khwe, Naypyitaw, Burma [BURMA].
 
MYANMA PEARL ENTERPRISE (a.k.a. MPE; a.k.a. MYANMAR PEARL ENTERPRISE), No. 4345, Bu Khwe, Naypyitaw, Burma [BURMA].
 
NO. 1 MINING ENTERPRISE, 90 Kanbe Road, Yankin, Rangoon, Burma [BURMA].
 
NO. 2 MINING ENTERPRISE, 90 Kanbe Road, Yankin, Rangoon, Burma [BURMA].
 
NO. 3 MINING ENTERPRISE, 90 Kanbe Road, Yankin, Rangoon, Burma [BURMA].

There were also changes to licenses and other aspects of the Burmese program, but that is another post for another day.

Link: 

OFAC Notice


Filed under: Burma Sanctions, OFAC Updates, Sanctions Lists
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May 18, 2016: SECO updates Iran sanctions

May 20, 2016, 7:41 am
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On Wednesday, Swiss regulators delisted the following individuals listed under the Iran sanctions program: 

 

SSID: 80-13085 Foreign identifier: 5. Name: Hamedani Hossein
Justification: Head of the IRGC’s Rassoulollah Corps in charge of Greater Tehran since November 2009. The Rassoulollah Corps is in charge of security in greater Tehran, and played a key role in violent suppression of protesters in 2009. Responsible for the crackdown of protests through Ashura events (December 2009) and since. Modifications: De-listed on 18 May 2016

SSID: 80-13418 Foreign identifier: 71. Name: Sharifi Malek Ajdar
Justification: Head of the judiciary in East Azerbaijan. Responsible for grave violations of the right to due process. Modifications: De-listed on 18 May 2016 

In addition, they amended 2 entities and 18 persons sanctioned under the program.

Links:

FINMA Notice

Data files of updates – PDF, XML


Filed under: Iranian Sanctions, Sanctions Lists, SECO Updates
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May 20, 2016: EU, HMT add 19 to DPRK sanctions

May 23, 2016, 6:44 am
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On Friday, Her Majesty’s Treasury (HMT) implemented Commission Implementing Regulation (EU) No 2016/780 by adding the following persons: 

 

  1. CHOE Kyong-Song
    Title:     Colonel General Other Information: EU not UN Listing. Former Member of the Central Military Commission of the Workers Party of Korea. Responsible for supporting or promoting the DPRK’s nuclear related, ballistic-missile-related or other weapons of mass destruction-related programmes. Listed on: 10/05/2016 Last Updated: 20/05/2016 Group ID: 13356.
  2. CHOE Yong-Ho
    Title:     Colonel General Other Information: EU not UN Listing. Former Member of the Central Military Commission of the Workers Party of Korea. Responsible for supporting or promoting the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes. Listed on: 10/05/2016 Last Updated: 20/05/2016 Group ID: 13357.
  3. HONG Yong Chil
    Position:     Deputy Director of the Munitions Industry Department Other Information: EU not UN Listing. Vice-Director Workers’ Party of Korea Central Committee. Responsible for supporting or promoting the DPRK’s nuclear related, ballistic missile related or other weapons of mass destruction related programmes. Listed on: 11/05/2016 Last Updated: 20/05/2016 Group ID: 13372.
  4. HUNG Sung Mu
    Position:     Deputy Director of the Munitions Industry Department Other Information: EU not UN Listing. Responsible for supporting or promoting the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes. Listed on: 10/05/2016 Last Updated: 20/05/2016 Group ID: 13358.
  5. JO Chun Ryong
    Position:     Chairman of the Second Economic Committee Other Information: EU not UN Listing. Member of the National Defence Commission. Responsible for supporting or promoting the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes. Listed on: 10/05/2016 Last Updated: 20/05/2016 Group ID: 13359. 

 

  1. JO Kyongchol
    Title:     General Other Information: EU not UN Listing. Former Member of the Central Military Commission of the Workers Party of Korea. Responsible for supporting or promoting the DPRK’s nuclear-related, ballistic missile related or other weapons of mass destruction related programmes. Listed on: 10/05/2016 Last Updated: 20/05/2016 Group ID: 13360.
  2. KIM Chun Sam
    Title:     Lieutenant General Other Information: EU not UN Listing. Former Member of the Central Military Commission of the Workers Party of Korea. Director of the Operations Department of the Military HQ. Responsible for supporting or promoting the DPRK’s nuclear related, ballistic missile related or other weapons of mass destruction related programmes. Listed on: 10/05/2016 Last Updated: 20/05/2016 Group ID: 13362.
  3. KIM Chun Sop
    Position:     Member of the National Defence Commission Other Information: EU not UN Listing. Responsible for supporting or promoting the DPRK’s nuclear related, ballistic missile related or other weapons of mass destruction related programmes. Listed on: 10/05/2016 Last Updated: 20/05/2016 Group ID: 13363.
  4. KIM Jong Gak
    Title:     Vice Marshal DOB: 20/07/1941. POB: Pyongyang Other Information: EU not UN Listing. Former Member of the Central Military Commission of the Workers Party of Korea. Responsible for supporting or promoting the DPRK’s nuclear related, ballistic missile related or other weapons of mass destruction related programmes. Listed on: 10/05/2016 Last Updated: 20/05/2016 Group ID: 13364.
  5. KIM Rak Kyom
    Title:     General a.k.a: KIM, Rak gyom Position: Four Star General, Commander of the Strategic Forces Other Information: EU not UN Listing. Four Star General, Commander of the Strategic Forces (aka Strategic Rocket Forces). Former Member of the Central Military Commission of the Workers Party of Korea. Responsible for supporting or promoting the DPRK’s nuclear related, ballistic missile related or other weapons of mass destruction related programmes. Listed on: 10/05/2016 Last Updated: 20/05/2016 Group ID: 13365.
  6. KIM Won Hong
    Title:     General DOB: 07/01/1945. POB: Pyongyang Passport Details: No: 745310010 Position: Director of the State Security Department, Minister of State Security Other Information: EU not UN Listing. Member of the Central Military Commission of the Workers Party of Korea & National Defence Commission. Responsible for supporting or promoting the DPRK’s nuclear related, ballistic missile related or other weapons of mass destruction related programmes. Listed on: 10/05/2016 Last Updated: 20/05/2016 Group ID: 13366.
  7. PAK Jong Chon
    Title:     General Colonel Position: Chief of the Korean People’s Armed Forces Other Information: EU not UN Listing. Deputy Chief of Staff & Director of the Firepower Command Department, Chief of the Military Headquarters and Director of the Artillery Command Department. Former Member of the Central Military Commission of the Workers Party of Korea. Responsible for supporting or promoting the DPRK’s nuclear-related, ballistic missile related or other weapons of mass destruction related programmes. Listed on: 10/05/2016 Last Updated: 20/05/2016 Group ID: 13367.
  1. PAK Yong Sik
    Title:     General Position: Member of the State Security Department Other Information: EU not UN Listing. Minister of Defence. Member of the Central Military Commission of the Workers Party of Korea and of the National Defence Commission. Responsible for supporting or promoting the DPRK’s nuclear related, ballistic missile related or other weapons of mass destruction related programmes. Listed on: 11/05/2016 Last Updated: 20/05/2016 Group ID: 13371.
  2. RI Hak Chol
    DOB:     (1) 19/01/1963. (2) 08/05/1966. a.k.a: (1) RI, Hak, Cheol (2) RI, Hak, Chul Passport Details: 381320634 PS 563410163 Position: President of Green Pine Associated Corporation Other Information: EU not UN Listing. Green Pine has been designated by the United Nations Security Council. Listed on: 11/05/2016 Last Updated: 20/05/2016 Group ID: 13373.
  3. RI Jong Su
    Title:     Vice Admiral Position: Commander in Chief of the Korean Navy. Other Information: EU not UN Listing. Former Member of the Central Military Commission of the Workers Party of Korea. Responsible for supporting or promoting the DPRK’s nuclear related, ballistic missile related or other weapons of mass destruction related programmes Listed on: 11/05/2016 Last Updated: 20/05/2016 Group ID: 13369.
  4. SON CHOL JU
    Title:     Colonel General Position: Colonel General of the Korean People’s Armed Forces & Political Director of the Air & Anti-air Forces. Other Information: EU not UN Listing. Responsible for supporting or promoting the DPRK’s nuclear related, ballistic missile related or other weapons of mass destruction related programmes. Listed on: 11/05/2016 Last Updated: 20/05/2016 Group ID: 13368.
  5. YUN Chang Hyok
    DOB:     09/08/1965. Position: Deputy Director of the Satellite Control Centre, National Aerospace Development Administration Other Information: EU not UN Listing. Responsible for supporting or promoting the DPRK’s nuclear related, ballistic missile related or other weapons of mass destruction related programmes. Listed on: 11/05/2016 Last Updated: 20/05/2016 Group ID: 13374.
  6. YUN Jong Rin
    Title:     General Other Information: EU not UN Listing. Former Member of the Central Military Commission of the Workers Party of Korea & of the National Defence Commission. Responsible for supporting or promoting the DPRK’s nuclear related, ballistic missile related or other weapons of mass destruction related programmes. Listed on: 11/05/2016 Last Updated: 20/05/2016 Group ID: 13370. 

and entity:

 

1. STRATEGIC ROCKET FORCES
Other Information: EU not UN Listing. Within the DPRK National Armed Forces, this entity is involved in the development and operational implementation of ballistic missile related or other weapons of mass destruction related programmes. Listed on: 11/05/2016 Last Updated: 20/05/2016 Group ID: 13375. 

to the sanctions against North Korea.

In addition, the following listings were amended:

 

CHU KYU-CHANG, Kyu ChangCHU
DOB: (1) –/–/1928. (2) –/–/1929. (3) –/–/1930. (4) –/–/1931. (5) –/–/1932. (6) — /–/193325/11/1928. POB: South Hamgyo’ng Province a.k.a: KYU-CHANG, JuJU, Kyu- Chang Position: First Deputy Director of the Defence Industry Department (ballistics programme), Korean Workers’ Party. Member of the National Defence
Commission Other Information: Annex V. EU listing. Not UN. Former Director of the Department of Munitions of the Central Committee of the Korean Workers’ Party. Responsible for supporting or promoting the DPRK’s nuclear related, ballistic missile related or other weapons of mass destruction-related programmes. Listed on: 30/12/2009 Last Updated: 30/12/2009 20/05/2016 Group ID: 11029.

SE-BONGPAEK, PAEK Se bong
DOB: –/–/1946. Position: Chairman of the Second Economic Committee (responsible for the ballistics programme) of the Central Committee of the Korean Workers’ Party. Member of the National Defence Commission Other Information: Annex V. EU listing. Not UN. Former Chairman of the Second Economic Committee (responsible for the ballistics programme) of the Central Committee of the Korean Workers’ Party. Listed on: 30/12/2009 Last Updated: 30/12/200920/05/2016 Group ID: 11035. 

Links:

HMT Notice

Commission Implementing Regulation (EU) No 2016/780


Filed under: EU Updates, HMT Updates, North Korea (DPRK) Sanctions, Sanctions Lists
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May 19, 2016: SECO updates North Korea sanctions

May 23, 2016, 6:51 am
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Yesterday, Swiss regulators added the following cargo vessels: 

 

SSID: 150-34423 Name: Chol Ryong
Good quality a.k.a.: Ryong Gun Bong
Other information: IMO Number: 8606173 Modifications: Listed on 18 May 2016

SSID: 150-34428 Name: Chong Bong
Good quality a.k.a.: a) Greenlight b) Blue Nouvelle
Other information: IMO Number: 8909575 Modifications: Listed on 18 May 2016

SSID: 150-34434 Name: Chong Rim 2
Other information: IMO Number: 8916293 Modifications: Listed on 18 May 2016

SSID: 150-34438 Name: Dawnlight
Other information: IMO Number: 9110236 Modifications: Listed on 18 May 2016

SSID: 150-34442 Name: Ever Bright 88
Good quality a.k.a.: J Star
Other information: IMO Number: 8914934 Modifications: Listed on 18 May 2016

SSID: 150-34447 Name: Gold Star 3
Good quality a.k.a.: Benevolence 2
Other information: IMO Number: 8405402 Modifications: Listed on 18 May 2016

SSID: 150-34452 Name: Hoe Ryong
Other information: IMO Number: 9041552 Modifications: Listed on 18 May 2016

SSID: 150-34456 Name: Hu Chang
Good quality a.k.a.: O Un Chong Nyon
Other information: IMO Number: 8330815 Modifications: Listed on 18 May 2016

SSID: 150-34461 Name: Hui Chon
Good quality a.k.a.: Hwang Gum San 2
Other information: IMO Number: 8405270 Modifications: Listed on 18 May 2016 

 

SSID: 150-34466 Name: Ji Hye San
Good quality a.k.a.: Hyok Sin 2
Other information: IMO Number: 8018900 Modifications: Listed on 18 May 2016

SSID: 150-34471 Name: Kang Gye
Good quality a.k.a.: Pi Ryu Gang
Other information: IMO Number: 8829593 Modifications: Listed on 18 May 2016

SSID: 150-34476 Name: Mi Rim
Other information: IMO Number: 8713471 Modifications: Listed on 18 May 2016

SSID: 150-34480 Name: Mi Rim 2
Other information: IMO Number: 9361407 Modifications: Listed on 18 May 2016

SSID: 150-34484 Name: O Rang
Good quality a.k.a.: Po Thong Gang
Other information: IMO Number: 8829555 Modifications: Listed on 18 May 2016

SSID: 150-34489 Name: Orion Star
Good quality a.k.a.: Richocean
Other information: IMO Number: 9333589 Modifications: Listed on 18 May 2016

SSID: 150-34494 Name: Ra Nam 2
Other information: IMO Number: 8625545 Modifications: Listed on 18 May 2016

SSID: 150-34498 Name: Ranam 3
Other information: IMO Number: 9314650 Modifications: Listed on 18 May 2016

SSID: 150-34502 Name: Ryo Myong
Other information: IMO Number: 8987333 Modifications: Listed on 18 May 2016

SSID: 150-34506 Name: Ryong Rim
Good quality a.k.a.: Jon Jin 2
Other information: IMO Number: 8018912 Modifications: Listed on 18 May 2016

SSID: 150-34511 Name: Se Pho
Good quality a.k.a.: Rak Won 2
Other information: IMO Number: 8819017 Modifications: Listed on 18 May 2016

SSID: 150-34516 Name: Songjin
Good quality a.k.a.: Jang Ja San Chong Nyon Ho
Other information: IMO Number: 8133530 Modifications: Listed on 18 May 2016

SSID: 150-34521 Name: South Hill 2
Other information: IMO Number: 8412467 Modifications: Listed on 18 May 2016

SSID: 150-34525 Name: South Hill 5
Other information: IMO Number: 9138680 Modifications: Listed on 18 May 2016

SSID: 150-34529 Name: Tan Chon
Good quality a.k.a.: Ryong Gang 2
Other information: IMO Number: 7640378 Modifications: Listed on 18 May 2016 

 

SSID: 150-34534 Name: Thae Pyong San
Good quality a.k.a.: Petrel 1
Other information: IMO Numbe: 9009085 Modifications: Listed on 18 May 2016

SSID: 150-34539 Name: Tong Hung San
Good quality a.k.a.: Chong Chon Gang
Other information: IMO Number: 7937317 Modifications: Listed on 18 May 2016

SSID: 150-34544 Name: Tong Hung 1
Other information: IMO Number: 8661575 Modifications: Listed on 18 May 2016 

to their North Korean sanctions program. That makes SECO the only sanctions regulator (other than OFAC) that explicitly sanctions vessels – when the UN listed cargo vessels, it was only in an Annex and not actually added to their sanctions files.

Links:

FINMA Notice

Data files of updates – PDF, XML


Filed under: North Korea (DPRK) Sanctions, Sanctions Lists, SECO Updates
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New Hong Kong Securities and Futures Commission AML/CFT Circular

May 24, 2016, 6:36 am
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On May 3rd, the Hong Kong Securities and Futures Commission (SFC) issued a Circular outlining recent international sanctions updates. This time, it’s just a bunch of updates from the United Nations ISIL (Da’esh) and Al-Qaida Sanctions Committee. As usual, the SFC includes a link to a PDF of the UN’s web notices – in this case, a single update which added 5 persons to the sanctions list.

Links:

HK SFC Notice

HK SFC Circular

UN Web Notice


Filed under: Al-Qaida Sanctions, HK Securities and Futures Commission, Islamic State/ISIS/ISIL, Sanctions Lists, Terrorism, UN Updates
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May 17, 2016: Significant changes to OFAC Burma program

May 25, 2016, 7:30 am
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OFAC says it best:
 
Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Burmese Sanctions Regulations, 31 C.F.R. part 537 (“the Regulations”), and updated the Specially Designated Nationals and Blocked Persons (SDN) List.  Specifically, OFAC issued regulatory amendments intended to support trade with Burma; facilitate the movement of goods within Burma; allow certain transactions related to U.S. individuals residing in Burma; and allow most transactions involving designated financial institutions.  In addition, OFAC, in consultation with the Department of State, removed seven state-owned enterprises and three state-owned banks from the SDN List.  Taken in concert with the regulatory amendments to allow most transactions with designated financial institutions, this leaves few OFAC restrictions remaining related to banks in Burma.  To incentivize further democratic reforms and maintain pressure on targeted individuals and entities and the military, certain sanctions remain in place.  As such, OFAC identified as blocked and added to the SDN List six companies that are owned 50 percent or more by Steven Law or Asia World Co. Ltd. (“Asia World”), persons who remain on the SDN List.  More broadly, these actions demonstrate the Administration’s support for continued political reforms and broad-based economic growth in Burma, while also maintaining sanctions pressure where needed, and providing the private sector with further clarity to effectively engage in Burma.  
 
“Burma reached a historic milestone over the last year by holding competitive elections and peacefully transitioning to a democratically-elected government.  Our actions today demonstrate our strong support for this political and economic progress while continuing to pressure designated persons in Burma to change their behavior,” said Adam J. Szubin, Acting Under Secretary for Terrorism and Financial Intelligence.  “These steps will help to facilitate trade with non-sanctioned businesses  and, in turn, help the people and Government of Burma achieve a more inclusive and prosperous future.”
Amendments to the Burmese Sanctions Regulations
 
Today, OFAC added a general license authorizing transactions related to U.S. person individuals residing in Burma, extended and expanded an existing general license authorizing trade-related transactions, and updated an existing general license authorizing certain banking services.  As background, an OFAC license is an authorization to engage in a transaction that otherwise would be prohibited.  There are two types of licenses: general licenses and specific licenses.  A general license broadly authorizes a particular type of transaction, subject to certain conditions, without the need to individually apply for a specific license. 
 
General license authorizing personal transactions related to U.S. persons residing in Burma
 
OFAC added a general license that allows U.S. persons to conduct most transactions otherwise prohibited by the Regulations that are ordinarily incident to U.S. person individuals residing in Burma.  This includes paying rent and other living expenses and buying goods and services for personal use.  
 
This complements the existing exemption in the Regulations for travel to or from Burma and will make it easier for U.S. persons to reside and work in Burma, which will increase opportunities for U.S. and Burmese persons to engage with each other.
 
General licenses authorizing trade-related transactions
 
OFAC made two regulatory amendments related to trade-related transactions.  First, OFAC extended indefinitely General License 20.  Initially issued for a six-month period in December 2015, this general license is now incorporated into the Regulations.  It authorizes transactions that are ordinarily incident to exports to or from Burma that are otherwise prohibited involving an individual or company that is designated or otherwise blocked by OFAC’s sanctions.  Second, to further support trade-related transactions, OFAC expanded this authorization by adding a general license permitting certain transactions incident to the movement of goods within Burma. This includes transactions such as transporting goods from a warehouse in Burma for further distribution to retail outlets in Burma. 
 
Together, these amendments will facilitate commerce into and throughout Burma, in turn bolstering trade and commercial opportunities for U.S. and Burmese exporters.  

  

Updating the general license authorizing certain banking services
 
OFAC is also updating an existing general license that authorizes most transactions involving all currently designated financial institutions in Burma.  Two of the financial institutions that were included in this license – Myanma Economic Bank and Myanma Investment and Commercial Bank – are being delisted today.  As engagement with them is no longer prohibited, this authorization is no longer needed and these two financial institutions are being removed from the general license.  Concurrently, OFAC is adding to the general license two other Burmese financial institutions that are currently designated – Innwa Bank and Myawaddy Bank – thereby authorizing most transactions involving all Burmese financial institutions once the amendment takes effect on May 18.   
 
This amendment will help encourage trade and increase economic opportunities for the Burmese people.  

Links:

OFAC Notice

Updated Burma Sanctions Regulations


Filed under: Burma Sanctions, Licenses, OFAC Updates, Sanctions Regulations
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OFAC’s LIBYA3 Executive Order

May 26, 2016, 6:06 am
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Section 1 of Executive Orders define the underlying behaviors being sanctioned, so let’s skip to the chase and show that for the latest US Executive Order on Libya. People are sanctioned if they are found:

 

(i) to be responsible for or complicit in, or to have engaged in, directly or indirectly, any of the following:

(A) actions or policies that threaten the peace, security, or stability of Libya, including through the supply of arms or related materiel;

(B) actions or policies that obstruct, undermine, delay, or impede, or pose a significant risk of obstructing, undermining, delaying, or impeding, the adoption of or political transition to a Government of National Accord or a successor government;

(C) actions that may lead to or result in the misappropriation of state assets of Libya; or

(D) threatening or coercing Libyan state financial institutions or the Libyan National Oil Company;

(ii) to be planning, directing, or committing, or to have planned, directed, or committed, attacks against any Libyan state facility or installation (in- cluding oil facilities), against any air, land, or sea port in Libya, or against any foreign mission in Libya;

(iii) to be involved in, or to have been involved in, the targeting of civilians through the commission of acts of violence, abduction, forced displacement, or attacks on schools, hospitals, religious sites, or locations where civilians are seeking refuge, or through conduct that would con- stitute a serious abuse or violation of human rights or a violation of international humanitarian law;

(iv) to be involved in, or to have been involved in, the illicit exploitation of crude oil or any other natural resources in Libya, including the illicit production, refining, brokering, sale, purchase, or export of Libyan oil;

(v) to be a leader of an entity that has, or whose members have, engaged in any activity described in subsections (a)(i), (a)(ii), (a)(iii), or (a)(iv) of this section;

(vi) to have materially assisted, sponsored, or provided financial, material, logistical, or technological support for, or goods or services in support of (A) any of the activities described in subsections (a)(i), (a)(ii), (a)(iii), or (a)(iv) of this section or (B) any person whose property and interests in property are blocked pursuant to this order; or

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

The rest is pretty standard – Section 2 bars immigration, Section 3 is about donations, Section 5 is about evasion and avoidance, etc.


Filed under: Executive Orders, Libya Sanctions, OFAC Updates
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May 25, 2016：OFAC adds two entities to terror list

May 30, 2016, 6:43 am
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On Wednesday, OFAC added the following 2 entities: 

JAMA’AT UL DAWA AL-QU’RAN (a.k.a. ASSEMBLY FOR THE CALL OF THE KORAN AND THE SUNNAH; a.k.a. JAMA’AT AD-DA’WA AS-SALAFIYA WA-L-QITAL; a.k.a. JAMAAT AL DAWA ILA AL SUNNAH; a.k.a. JAMA’AT AL-DA’WA ALA-L-QURAN WA-L-SUNNA; a.k.a. JAMA’AT DA’WA AL-SUNNAT; a.k.a. JAMAAT UD DAWA IL AL QURAN AL SUNNAH; a.k.a. JAMAAT UL DAWA AL QURAN; a.k.a. JAMAAT-UD-DAWA AL QURAN WAL SUNNAH; a.k.a. JAMIAT AL-DAWA AL-QURAN WAL-SUNNA; a.k.a. SOCIETY FOR THE CALL/INVITATION TO THE QURAN AND THE SUNNA; a.k.a. “JDQ”; a.k.a. “JDQS”; a.k.a. “SALAFI GROUP”), Afghanistan [SDGT].
TARIQ GIDAR GROUP (a.k.a. COMMANDER TARIQ AFRIDI GROUP; a.k.a. TARIQ AFRIDI GROUP; a.k.a. TARIQ GEEDAR GROUP; a.k.a. TARIQ GIDAR AFRIDI GROUP; a.k.a. TEHREEK-I-TALIBAN PAKISTAN GEEDAR GROUP; a.k.a. TEHRIK-E-TALIBAN-TARIQ GIDAR GROUP; a.k.a. TTP GEEDAR GROUP; a.k.a. TTP-TARIQ GIDAR GROUP; a.k.a. “TGG”; a.k.a. “THE ASIAN TIGERS”), Darra Adam Khel, Pakistan; Aurakzai, Pakistan; Khyber, Pakistan; Peshawar, Pakistan; Kohat, Pakistan; Hangu, Pakistan [SDGT].

to its Specially Designated Nationals (SDN) List under its counter-terrorism sanctions program. 

Link:

OFAC Notice


Filed under: OFAC Updates, Sanctions Lists, Terrorism
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May 27, 2016: DFAT adds to autonomous DPRK sanctions

June 1, 2016, 6:31 am
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On Friday, Australia designated the following person under the Autonomous Sanctions Regulations for North Korea: 

Name of Individual:

Jacob Steiger

 

Date of Birth:

27/04/1941

 

Place of Birth:

Altstatten, SG, Switzerland

 

Address:

c/o Kohas AG, Fribourg, FR, Switzerland

 

Listing Information:

Formerly listed on the RBA Consolidated List as 2006NKR0013

and they added the following “designated and declared” persons: 

1

Name of Individual:

Pak To-chun

 

Also known as (aka):

Pak To’-Ch’un; Pak Do Chun

 

Date of Birth:

09/03/1944

 

Place of Birth:

Namgim County, Chagang Province, North Korea

 

Address:

Pyongyang, North Korea

2

Name of Individual:

Ju Kyu-chang

 

Also known as (aka):

Chu Kyu-Ch’ang; Ju Kyu-Chang

 

Date of Birth:

25/11/1928

 

Place of Birth:

Hamju County, South Hamgyong Province, North Korea

 

Address:

Pyongyang, North Korea

3

Name of Individual:

O Kuk-ryol

 

Also known as (aka):

O Ku’k-ryo’l

 

Date of Birth:

07/01/1930

 

Place of Birth:

Onsong County, North Hamgyong Province, North Korea

 

Address:

Pyongyang, North Korea

4

Name of Individual:

Paek Se-bong

 

Also known as (aka):

Paek Se Pong

 

Date of Birth:

21/03/1938

 

Additional Information:

Chairman, Second Economic Committee 

 

Address:

Pyongyang, North Korea

5

Name of Individual:

Su Lu-chi

 

Also known as (aka):

Lu-Chi Tsai Su; Tsai Su Lu-Chi; Su Luqi; Liu-chi Su

 

Date of birth:

07/02/1950

 

Alternative Date of Birth:

November 1950

 

Place of Birth:

Yun Lin Hsien, Taiwan

 

Passport Information:

210215095 (Taiwan)

 

Additional Information:

Corporate Officer, Global Interface Company Inc 

 

Address:

Taipei, Taiwan

6

Name of Individual:

Alex Tsai

 

Also known as (aka):

Tsai Hsein Tai; Hsein Tai Tsai

 

Date of Birth:

08/08/1945

 

Place of Birth:

Tainan, Taiwan

 

Passport Information:

131134049 (Taiwan)

 

Additional Information:

General Manager, Global Interface Company Inc

 

Address:

Taipei, Taiwan

7

Name of Individual:

Kim Yong-chol

 

Also known as (aka):

Lieutenant General Kim Yong Chol; Kim Yong-Chol; 
Kim Young-Chol; Kim Young-Cheol; Kim Young-Chul

 

Date of Birth:

circa 1947

 

Alternative Date of Birth:

circa 1946

 

Location:

Pyongan-Pukto, North Korea

 

Additional Information:

Commander of Reconnaissance General Bureau (RGB) 

 

Address:

Pyongyang, North Korea

8

Name of Individual:

Chang Wen-fu

 

Also known as (aka):

Tony Chang; Zhang Wen-Fu

 

Date of Birth:

01/04/1965

 

Passport Information:

211606395 (Taiwan)

9

Name of Individual:

Kim Chol Sam

 

Date of Birth:

11/03/1971

 

Additional Information:

Treasurer, Daedong Credit Bank (DCB)

 

Address:

Pyongyang, North Korea

10

Name of Individual:

Son Mun San

 

Date of Birth:

23/01/1951

 

Additional Information:

External Affairs Bureau Chief, General Bureau of Atomic Energy, North Korea

11

Name of Individual:

Kil Jong Hun

 

Also known as (aka):

Kil Cho’ng-hun; Kil Chong-hun

 

Date of Birth:

20/02/1972

 

Additional Information:

Korea Mining Development Trading Corporation (KOMID) representative in Namibia

 

Passport Information:

472410022 (DPRK)

12

Name of Individual:

Kim Kwang Yon

 

Also known as (aka):

Kim Kwang-y’on

 

Date of Birth:

30/07/1966

 

Additional Information:

Korea Mining Development Trading Corporation (KOMID) representative in southern Africa

 

Passport Information:

563210059 (DPRK)

13

Name of Individual:

Jang Song Chol 

 

Also known as (aka):

Chang So’ng-ch’o’l; Chang Song-chol

 

Date of Birth:

12/03/1967

 

Additional Information:

Korea Mining Development Trading Corporation (KOMID) representative in Russia

14

Name of Individual:

Yu Kwang Ho

 

Date of Birth:

18/10/1956

15

Name of Individual:

Kim Yong Chol

 

Also known as (aka):

Kim Yo’ng-Ch’o’l; Kim Yong-Chol

 

Date of Birth:

18/02/1962

 

Additional Information:

Korea Mining Development Trading Corporation (KOMID) representative in Iran

16

Name of Individual:

Jang Yong Son 

 

Also known as (aka):

Chang Yo’ng-so’n; Chang Yong-son

 

Date of Birth:

20/02/1957

 

Additional Information:

Korea Mining Development Trading Corporation (KOMID) representative in Iran

17

Name of Individual:

Kim Kyu

 

Date of Birth:

30/07/1968

 

Additional Information:

Korea Mining Development Trading Corporation (KOMID) external affairs officer

18

Name of Individual:

Ryu Jin

 

Also known as (aka):

Ryu Chin

 

Date of Birth:

07/08/1965

 

Additional Information:

Korea Mining Development Trading Corporation (KOMID) representative in Syria

 

Passport Information:

563410081 (DPRK)

19

Name of Individual:

Kang Ryong

 

Date of Birth:

21/08/1968

 

Additional Information:

Korea Mining Development Trading Corporation (KOMID) representative in Syria

20

Name of Individual:

Kim Kwang Chun

 

Also known as (aka):

Kim Kwang-ch’un; Kim Kwang-chun

 

Date of Birth:

20/04/1967

 

Additional Information:

Korea Ryunseng Trading Corporation representative in Shenyang, China

21

Name of Individual:

Ra Kyong-su

 

Also known as (aka):

Chang Myong-ho; Shang Myong Ho

 

Date of Birth:

28/08/1962

 

Passport Information:

290320764

 

Additional Information:

Tanchon Commercial Bank (TCB) representative in Beijing

 

Address:

Beijing, China

22

Name of Individual:

Kim Sok-chol

 

Date of Birth:

08/05/1955

 

Passport Information:

472310082

 

Additional Information:

Previous DPRK Ambassador to Myanmar

 

Address:

Myanmar

23

Name of Individual:

Ri Chong-chol

 

Date of Birth:

12/04/1970

 

Passport Information:

199110092; 472220503; 654220197

 

Additional Information:

Linked to Korea Mining Development Trading Corporation (KOMID)

 

Address:

Pyongyang, North Korea

24

Name of Individual:

Hwang Su-man

 

Also known as (aka):

Hwang Kyong-nam

 

Date of Birth:

06/04/1955

 

Passport Information:

472220033

 

Additional Information:

Linked to Korea Mining Development Trading Corporation (KOMID)

 

Address:

Egypt

and the following to the list of designated entities:

1

Name of Entity:

Hesong Trading Corporation

 

Address:

Pyongyang, North Korea

 

Listing Information:

Formerly listed on the RBA Consolidated List as 2006NKR0003

2

Name of Entity:

Kohas AG

 

Address:

Route des Arsenaux 15, Fribourg, FR 1700, Switzerland; C.R. No. CH-217.0.135.79-4 (Switzerland)

 

Listing Information:

Formerly listed on the RBA Consolidated List as 2006NKR0012

3

Name of Entity:

Korea Complex Equipment Import Corporation

 

Address:

Rakwon-dong, Pothonggang District, Pyongyang, North Korea

 

Listing Information:

Formerly listed on the RBA Consolidated List as 2006NKR0008

4

Name of Entity:

Korea International Chemical Joint Venture Company

 

Also known as (aka):

a) Chosun International Chemicals Joint Operation Company, b) International Chemical Joint Venture Corporation, c) Choson International Chemicals Joint Operation Company

 

Address:

Hamhung, South Hangyong Province, North Korea; Mangyongdae-kuyok, Pyongyang, North Korea; Mangyungdae-gu, Pyongyang, North Korea

 

Listing Information:

Formerly listed on the RBA Consolidated List as 2006NKR0006

5

Name of Entity:

Korea Kwangsong Trading Corporation

 

Address:

Rakwon-dong, Pothonggang District, Pyongyang, North Korea

 

Listing Information:

Formerly listed on the RBA Consolidated List as 2006NKR0009

6

Name of Entity:

Korea Pugang Trading Corporation

 

Address:

Rakwon-dong, Pothonggang District, Pyongyang, North Korea

 

Listing Information:

Formerly listed on the RBA Consolidated List as 2006NKR0010

7

Name of Entity:

Korea Ryongwang Trading Corporation

 

Also known as (aka):

Korea Ryengwang Trading Corporation

 

Address:

Rakwon-dong, Pothonggang District, Pyongyang, North Korea

 

Listing Information:

Formerly listed on the RBA Consolidated List as 2006NKR0011

8

Name of Entity:

Korea Ryonha Machinery Joint Venture Corporation

 

Also known as (aka):

a) Korea Ryenha Machinery J/V Corporation, b) Chosun Yunha Machinery Joint Operation Company, c) Ryonha Machinery Joint Venture Corporation

 

Address:

Central District, Pyongyang, North Korea; Mangyungdae-gu, Pyongyang, North Korea; Mangyongdae District, Pyongyang, North Korea

 

Listing Information:

Formerly listed on the RBA Consolidated List as 2006NKR0007

9

Name of Entity:

Tosong Technology Trading Corporation

 

Address:

Pyongyang, North Korea

 

Listing Information:

Formerly listed on the RBA Consolidated List as 2006NKR0004

10

Name of Entity:

Foreign Trade Bank (FTB)

 

Address:

FTB Building, Jungsong-Dong, Central District, Pyongyang, North Korea

11

Name of Entity:

Global Interface Company Inc

 

Address:

9F-1, No 22, Hsin Yi Road, Sec 2, Taipei, Taiwan

 

Alternative Address:

1st Floor, No 49, Lane 280, Kuang Fu S Road, Taipei, Taiwan

 

Additional Information:

Business registration document 12873346

12

Name of Entity:

Korea Daesong General Trading Corporation 

 

Also known as (aka):

Daesong Trading

 

Address:

Pyongyang, North Korea

13

Name of Entity:

Trans Merits Co Ltd

 

Address:

1F, No 49, Lane 280, Kuang Fu S Road, Taipei, Taiwan

 

Additional information:

Business registration document 16316976

14

Name of Entity:

Korea Taesong Trading Company

 

Address:

Pyongyang, North Korea

15

Name of Entity:

Munitions Industry Department (MID)

 

Also known as (aka):

Military Supplies Industry Department; Machine Building Industry Department

 

Address:

Pyongyang, North Korea

16

Name of Entity:

Second Economic Committee (SEC)

 

Address:

Pyongyang, North Korea

17

Name of Entity:

Reconnaissance General Bureau (RGB)

 

Also known as (aka):

Korean People’s Army (KPA) Unit 586; Chongchal Chongguk KPA Unit 586

 

Address:

Pyongyang, North Korea

18

Name of Entity:

Office 39

 

Also known as (aka):

Bureau 39; Division 39; Office #39; Office No 39; Third floor; Central Committee

 

Address:

Second KWP Government Building, Chungsong-dong, Chung Ward, Pyongyang, North Korea

 

Alternative Address:

Sosong Street, Kyongrim-dong, Central District, Pyongyang, North Korea

19

Name of Entity:

Korea Daesong Bank

 

Address:

Pyongyang, North Korea

20

Name of Entity:

Korea Kwangson Banking Corporation (KKBC)

 

Address:

Pyongyang, North Korea

21

Name of Entity:

Daedong Credit Bank

 

Also known as (aka):

DCB; Dae-Dong Credit Bank; Taedong Credit Bank

 

Address:

Suite 401, Potonggang Hotel, Ansan-Dong, Pyongchon District, Pyongyang, North Korea

 

Alternative Address:

Ansan-dong, Botonggang Hotel, Pongchon, Pyongyang, North Korea

22

Name of Entity:

DCB Finance Ltd

 

Address:

Akara Building, 24 de Castro Street, Wickhams Cay I, Road Town, Tortola, British Virgin Islands

 

Alternative Address:

Dalian, China

23

Name of Entity:

Trans Multi Mechanics Co Ltd

 

Also known as (aka):

Feng Sheng Co Ltd

 

Address:

19, Chin Ho Lane, Chung Cheng Road, Taya District, Taichung City, Taiwan

 

Alternative Address:

No 19, Jinhe Lane, Zhongzheng Road, Daya District, Taichung City, Taiwan

24

Name of Entity:

Chongchongang Shipping Company

 

Also known as (aka):

Chongchongang Shipping CO Ltd; Chong Chon Gang Shipping Co Ltd

 

Address:

817 Haeun, Donghung-dong, Central District, Pyongyang, North Korea

 

Alternative address:

817 Haeun, Tonghun-dong, Chung-gu, Pyongyang, North Korea

 

IMO number

5342883

25

Name of Entity:

Haeyang Crew Management Company (HCMC)

 

Address:

Pyongyang, North Korea

 

Link:

Federal Register of Legislation link


Filed under: Autonomous Australian sanctions, DFAT Updates, North Korea (DPRK) Sanctions, Sanctions Lists
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May 27, 2016: EU ramps up DPRK sanctions

June 1, 2016, 6:41 am
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North Korea: EU adopts new restrictions on trade, financial services, investment and transport
 
 

On 27 May 2016, the Council adopted additional restrictive measures against the Democratic People’s Republic of Korea (DPRK). These measures complement and reinforce the sanctions regime imposed by United Nations Security Council (UNSC) resolutions. 

In response to the nuclear test conducted by the DPRK on 6 January 2016 and the launch using ballistic missile technology of 7 February, the UNSC adopted resolution 2270 on 2 March 2016 imposing additional restrictive measures against the DPRK. On 5 and 31 March 2016 the Council transposed  this resolution into EU law. 

Considering that the actions of the DPRK constitute a grave threat to international peace and security in the region and beyond, the EU decided to further expand its restrictive measures targeting the DPRK’s nuclear, weapons of mass destruction and ballistic missile programmes. These additional measures include: 

  • in the trade sector: prohibition of the import of petroleum products and luxury goods from the DPRK, prohibition of the supply, sale or transfer to the DPRK of additional items, materials, equipment relating to dual-use goods and technology and ban on any public financial support for trade with the DPRK;
  • in the financial sector: prohibition of transfers of funds to and from the DPRK, unless for certain predefined purposes and authorised in advance;
  • in terms of investment: prohibition of all investment by the DPRK in the EU; prohibition of investment by EU nationals or entities in the mining, refining and chemical industries sectors as well as in any entities engaged in the DPRK’s illegal programmes;
  • in the transport sector: prohibition on any aircraft operated by DPRK carriers or originating from the DPRK from landing in, taking off or overflying EU territory; prohibition on any vessel owned, operated or crewed by the DPRK from entering EU ports.

Link:

EU Notice


Filed under: EU Updates, North Korea (DPRK) Sanctions, Sanctions News
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Hizballah Financial Sanctions Regulations

June 2, 2016, 6:39 am
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From the Federal Register – Subpart B contains the meat of the regulations (i.e. What gets you sanctioned, and what sanctions are imposed). Note: This is not an asset-freezing sanctions regime – it’s more like the ISA sanctions program or the Part 561 sanctions program, with restrictions on parties assisting sanctioned parties:

 

Subpart B—Prohibitions

§ 566.201 Prohibitions or strict conditions with respect to correspondent or payable- through accounts of certain foreign financial institutions identified by the Secretary of the Treasury.

Upon a determination by the Secretary of the Treasury that a foreign financial institution knowingly engages in one or more of the activities described in paragraphs (a)(1) through (a)(4) of this section, the Secretary of the Treasury may, as set forth in paragraph (b) of this section, impose one or more strict conditions on the opening or maintaining of a correspondent account or a payable-through account in the United States for that foreign financial institution, or, as set forth in paragraph (c) of this section, prohibit a U.S. financial institution from opening or maintaining a correspondent account or a payable-through account in the United States for that foreign financial institution.

(a) A foreign financial institution engages in an activity described in this paragraph if, in any location or  currency, the foreign financial institution, on or after December 18, 2015, knowingly:

(1) Facilitates a significant transaction or transactions for Hizballah;

(2) Facilitates a significant transaction or transactions of a person identified on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), the property and interests in property of which are blocked pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA) for acting on behalf of or at the direction of, or being owned or controlled by, Hizballah;

Note to paragraph (a)(2): The SDN List is accessible through the following page on OFAC’s Web site: http://www.treasury.gov/sdn. Additional information pertaining to the SDN List can be found in appendix A to this chapter. Persons whose property and interests in property are blocked pursuant to IEEPA for acting on behalf of or at the direction of or being owned or controlled by Hizballah are identified by a special reference to Hizballah at the end of their entries on the SDN List, in addition to the reference to the regulatory part of this chapter pursuant to which their property and interests in property are blocked. For example, a person whose property and interests in property are blocked pursuant to the Global Terrorism Sanctions Regulations, 31 CFR part 594, and identified on the SDN List, will have the program tag ‘‘[SDGT]’’ and descriptive text [‘‘Subject to secondary sanctions pursuant to the Hizballah Financial Sanctions Regulations’’].

(3) Engages in money laundering to carry out an activity described in paragraphs (a)(1) or (a)(2) of this section; or

(4) Facilitates a significant transaction or transactions or provides significant financial services to carry out an activity described in paragraphs (a)(1), (a)(2), or (a)(3) of this section.

(b) The Secretary of the Treasury may impose one or more strict conditions on the opening or maintaining by a U.S. financial institution of a correspondent account or a payable-through account in the United States for a foreign financial institution that the Secretary finds engages in one or more of the activities described in paragraph (a) of this section. Except as otherwise authorized pursuant to this part, a U.S. financial institution shall not open or maintain a correspondent account or payable- through account in the United States in a manner that is inconsistent with any strict condition imposed and in effect pursuant to this paragraph. Such conditions may include the following:

(1) Prohibiting or restricting any provision of trade finance through the correspondent account or payable- through account of the foreign financial institution; 

 

(2) Restricting the transactions that may be processed through the correspondent account or payable- through account of the foreign financial institution to certain types of transactions, such as personal remittances;

(3) Placing monetary limits on, or limiting the volume of, the transactions that may be processed through the correspondent account or payable- through account of the foreign financial institution;

(4) Requiring pre-approval from the U.S. financial institution for all transactions processed through the correspondent account or payable- through account of the foreign financial institution; or

(5) Prohibiting or restricting the processing of foreign exchange transactions through the correspondent account or payable-through account of the foreign financial institution.

Note to paragraph (b): The name of the foreign financial institution, together with the actual strict condition(s) to be imposed, will be added to the HFSR List on the Office of Foreign Assets Control’s Web site (http://www.treasury.gov/ofac) on the Counter Terrorism Sanctions page, and published in the Federal Register.

(c) If the Secretary of the Treasury does not impose one or more strict conditions, pursuant to paragraph (b) of this section, on the opening or maintaining by a U.S. financial institution of a correspondent account or a payable-through account in the United States for a foreign financial institution that the Secretary determines engages in one or more of the activities described in paragraph (a) of this section, the Secretary may prohibit the opening or maintaining by a U.S. financial institution of a correspondent account or a payable-through account in the United States for that foreign financial institution. Except as otherwise authorized pursuant to this part, a U.S. financial institution shall not open or maintain a correspondent account or a payable-through account in the United States for a foreign financial institution for which the opening or maintaining of such an account is prohibited pursuant to this paragraph.

Note to paragraph (c): The names of foreign financial institutions for which the opening or maintaining of a correspondent account or a payable-through account in the United States is prohibited will be listed on the HFSR List on OFAC’s Web site (http://www.treasury.gov/ofac) on the Counter Terrorism Sanctions page, and published in the Federal Register. 

 

§ 566.202 Evasions; attempts; causing violations; conspiracies.

(a) Any transaction on or after the effective date that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions set forth in this part is prohibited.

(b) Any conspiracy formed to violate any of the prohibitions set forth in this part is prohibited. 


Filed under: Hizballah (HFSR) Sanctions, Hizballah / Hezbollah, OFAC Updates, Sanctions Regulations
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One more year for EU sanctions on Syria

June 2, 2016, 6:45 am
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Syria: EU extends sanctions against the regime by one year
 
 

On 27 May 2016, the Council extended EU restrictive measures against the Syrian regime until 1 June 2017. This decision is in line with the Council conclusions of December 2014 which affirmed that the EU would continue imposing and enforcing sanctions targeting the regime and its supporters as long as repression continues. 

The EU remains committed to finding a lasting solution to the conflict in Syria. As stated in the Council conclusions on Syria, Iraq as well as the Da’esh threat of 23 May 21016, the EU will further support the International Syria Support Group (ISSG) efforts to strengthen the implementation of the cessation of hostilities in Syria. The EU will step up its political role in support for a credible resumption of the intra-Syrian talkscoordinated by UN Special Envoy de Mistura aiming at reaching an agreement on a genuine political transition in Syria in accordance with the ISSG Vienna statement of 17 May 2016. The EU will also further support the delivery of humanitarian aid to all Syrians in need in besieged and hard to reach areas.

The sanctions currently in place include notably an oil embargo, restrictions on certain investments, a freeze of the assets of the Syrian central bank within the EU, export restrictions on equipment and technology that might be used for internal repression as well as on equipment and technology for monitoring or interception of internet or telephone communications. In addition, over 200 persons and 70 entities are targeted by a travel ban and an asset freeze over the violent repression against the civilian 

Link:

EU Notice


Filed under: EU Updates, Sanctions News, Syrian Sanctions
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OFAC Panama-related Kingpin FAQs

June 3, 2016, 6:44 am
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General Licenses Issued Authorizing Certain Activities Pertaining to Panama

470. What transactions and activities does General License 2 (Authorizing Certain Transactions and Activities Necessary to Wind Down Operations for the Hotel Operating at Millennium Plaza, Panama) authorize? 

If you are a U.S. person currently staying at the hotel operating at Millennium Plaza, Panama, you are authorized to continue your stay through 12:01 a.m. eastern daylight time, on May 26, 2016.

If you are a U.S. person with an upcoming reservation at the hotel scheduled to begin and conclude within the authorized 21 day window, you are authorized to stay at the hotel. 

If you are a U.S. person with an upcoming reservation at the hotel outside of the authorized 21 day window, General License 2 does not authorize you to stay at the hotel to the extent your stay is outside the authorized time. 

During any authorized stay U.S. persons are permitted to engage in other transactions insofar as they relate to lodging activities. For the purposes of this General License, lodging activities include payment for your hotel room, service charges, applicable taxes, meals, internet access, media, and transportation. Lodging does not include casino-related transactions or general retail-related transactions. [05-05-16]

471. What transactions and activities does General License 3 (Authorizing Certain Transactions and Activities Necessary to Maintain Existing Operations of La Estrella and El Siglo Newspapers) authorize? 

If you are a U.S. person providing services to La Estrella or El Siglo, you are authorized to continue providing those services through 12:01 a.m. eastern daylight time, on July 6, 2016. 

Services include, but are not limited to, the provision of paper, ink, and other printing supplies; web hosting; advertising; marketing; newspaper delivery; information dissemination via social media and other web applications; and publishing-related activities. U.S. persons are also authorized to engage in any other transaction that is related to the operations of the newspapers, including, but not limited to, necessary support services such as accounting, human resources, and information technology. [05-05-16]

472. What transactions and activities does General License 4A (Authorizing Certain Transactions Involving Individuals or Entities Located in the Panamanian mall, Soho Panama S.A. (a.k.a. Soho Mall Panama)) authorize? 

If you are a U.S. person currently transacting, operating, or otherwise engaged in dealings with a non-designated individual or entity located at the Panamanian mall and associated complex, Soho Panama, S.A. (a.k.a. Soho Mall Panama), you are authorized to engage in transactions and other activities provided that those transactions and activities are for the wind down of operations, contracts, and other agreements; are related to building services; or are related to the provision of financial services; provided that the transactions and activities are not with a designated individual or entity and do not involve orders for shipment of goods to the mall placed after the date of designation. These transactions and other activities are authorized through 12:01 a.m. eastern daylight time on July 6, 2016.

These authorized transactions and activities include: (1) the completion of shipments provided that they do not involve any orders for goods placed after the date of designation; (2) re-location, liquidation, or disposition of existing inventory; (3) processing of transactions and provision of financial services by non-designated persons operating at the mall and complex, including salary payments; (4) the provision of goods and services related to building maintenance; and (5) other transactions incident to the wind down of operations, contracts, or other agreements, insofar as they do not include payments, including rent payments, to the mall and complex. Any transactions carried out directly with any designated entity are prohibited as are any new orders for shipment of goods to Soho Panama, S.A. (a.k.a. Soho Mall Panama).

Payments made by non-designated individuals or entities located in the designated mall and associated complex, to or for the benefit of Soho Panama S.A. or Westline Enterprises, Inc., are required to be made into a blocked interest-bearing account in accordance with 31 C.F.R. 598.206(a).

A person wishing to conduct a transaction or activity not covered by an OFAC General License should submit an online specific license application to OFAC. [05-05-16]

473. What transactions and activities does General License 5 (Authorizing Certain Transactions and Activities Related to the Panamanian Seizure of Balboa Bank & Trust) authorize? 

If you are a U.S. person, you are authorized to engage in all transactions and activities necessary for the analysis of, and recommendations regarding, the financial viability of Balboa Bank & Trust being conducted by the appointed administrator. 

These transactions and activities include the export, re-export, and provision of software, hardware, and other information technology-related goods and services; goods and services related to payroll, building utilities, building insurance, building maintenance, building security, and infrastructure; and goods and services related to auditing, consulting, legal, and other professional services. The authorization also includes U.S. persons providing information necessary for the administrator’s analysis and recommendations regarding the financial viability of Balboa Bank & Trust. [05-13-2016] 

474. What transactions and activities does General License 6 (Authorizing Certain Transactions and Activities Related to the Panamanian Intervention of Balboa Securities) authorize? 

If you are a U.S. person, you are authorized to engage in all transactions and activities necessary for the appointed administrator’s inventory of assets and liabilities, and development of a final report, on Balboa Securities, Corp. 

These transactions and activities include the export, re-export, and provision of software, hardware, and other information technology-related goods and services; goods and services related to payroll, building utilities, building insurance, building maintenance, and building security; and goods and services related to auditing, consulting, legal, and other professional services. The General License also authorizes U.S. persons to provide information necessary for the administrator’s inventory and report on Balboa Securities, Corp. [05-13-2016] 

 

Link:

OFAC Panama Related Kingpin Act Frequently Asked Questions


Filed under: Frequently Asked Questions (FAQ), Licenses, Narcotics Trafficking, OFAC Updates
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June 2, 2016: HMT announced EU expansion of DPRK sanctions

June 6, 2016, 6:29 am
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On May 28th, the EU adopted Council Regulation (EU) No 2016/841, which makes the following changes to sanctions on North Korea:

 

With effect from 29 May 2016 it is prohibited to:

  1. i  Transfer funds to and from North Korea unless the funds are for a specific purpose as listed in the Regulation;
  2. ii  Transfer any funds over EUR 15,000 without specific authorisation from HM Treasury and;
  3. iii  Provide financial support for trade with North Korea; and
  4. iv  Accept or approve investment in any commercial activity as detailed in the

    Regulation. 

Links:

HMT Notice

Council Regulation (EU) No 2016/841


Filed under: EU Updates, HMT Updates, North Korea (DPRK) Sanctions, Sanctions Regulations, Uncategorized
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June 2, 2016: OFAC makes Burundi designations

June 6, 2016, 6:40 am
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On Thursday, OFAC designated the following 3 people: 

NGENDABANKA, Marius, Kinanira IV, Kinindo, Bujumbura, Burundi; DOB 25 Aug 1974; nationality Burundi; Gender Male; Commander, First Military Region; Deputy Chief of Land Forces; Burundian National Defense Forces Deputy Commander of Operations (individual) [BURUNDI]. 
 
NSHIMIRIMANA, Edouard; DOB 1970; POB Bugeni Vyanda, Burundi; nationality Burundi; Passport 089567 (Burundi) issued 10 Feb 2006 expires 10 Feb 2011; Former Lieutenant Colonel (individual) [BURUNDI]. 
 
SIBOMANA, Ignace; DOB 01 Jan 1972; POB Buhina, Kanyosha, Bujumbura, Burundi; nationality Burundi; Gender Male; Burundian Army Colonel, Chief of Military Intelligence (individual) [BURUNDI].

under the Burundi sanctions program.

Link:

OFAC Notice


Filed under: Burundi sanctions, OFAC Updates, Sanctions Lists
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June 3, 2016: Mawa Enterprises Corp. Removed from Kingpin sanctions

June 6, 2016, 6:44 am
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June 3, 2016: OFAC Publishes Kingpin General License 3A

June 6, 2016, 6:46 am
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June 3, 2016: EU, HMT removes 2, amends 17 Syrian sanctions listings

June 6, 2016, 7:13 am
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On Friday, Her Majesty’s Treasury (HMT) adopted Council Implementing Regulation (EU) Np 2016/840 by removing the following 2 persons from its Syrian sanctions program: 

 

FARAHAT, Mohamed
a.k.a: FARAHAT, Muhammad Position: Vice-President of Finance and Administration at Tri-Ocean Energy Other Information: Tri-Ocean Energy is a listed entity. Listed on: 22/10/2014 Last Updated: 29/05/2016 Group ID: 13163

KHAYRBIK, Muhammad
DOB: (1) 10/04/1937. (2) 20/05/1937. POB: Hama a.k.a: (1) KHAYRBIK, Mohamad,
Naseef (2) KHAYRBIK, Mohamad, Nasier (3) KHAYRBIK, Mohamad, Nasif (4) KHAYRBIK, Mohamad, Nasseef (5) KHAYRBIK, Mohamad, Nassif (6) KHAYRBIK, Muhammad,
Naseef (7) KHAYRBIK, Muhammad, Nasier (8) KHAYRBIK, Muhammad,
Nasseef (9) KHAYRBIK, Muhammad, Nassif (10) KHIER BEK, Mohamad,
Naseef (11) KHIER BEK, Mohamad, Nasier (12) KHIER BEK, Mohamad, Nasif (13) KHIER BEK, Mohamad, Nasseef (14) KHIER BEK, Mohamad, Nassif (15) KHIER BEK, Muhammad, Naseef (16) KHIER BEK, Muhammad, Nasier (17) KHIER BEK, Muhammad,
Nasif (18) KHIER BEK, Muhammad, Nasseef (19) KHIER BEK, Muhammad,
Nassif Passport Details: 0002250 (Diplomatic) Position: Deputy Vice-President of Syria for National Security Affairs Listed on: 24/05/2011 Last Updated: 29/05/2016 Group ID: 11932. 

and amending the following 17 listings:

 

  1. MAKHLOUF, Rami
    DOB:     10/07/1969. POB: Damascus Passport Details: 454224 Other Information: Syrian businessman operating in Syria with interests in telecommunications, financial services, transport and property sectors. He is an influential member of the Makhlouf family and closely connected to the Assad family. Cousin of President Bashar Al- Assad. Has financial interests in and/or holds senior positions in Al Mahreq Mashreq Bena Properties, Cham Holding and Syriatel. Listed on: 10/05/2011 Last Updated: 01/06/2016 Group ID: 11913.
  2. HAMCHO, Mohammed
    DOB:     20/05/1966. Passport Details: 002954347 Other Information: Leading Syrian businessman with interests in the engineering and construction, media, hospitality and health sector. owner Has financial interests in and/or holds senior positions in Hamsho International, Hamsho Communications, Mhg International, Jupiter for Investment and Tourism Project and Syria Metal Industries. of Hamcho International, Close to key figures of the Syrian regime, including President Bashar al-Assad and Maher al-Assad. Since March 2014, he has held the position He is Chairman of the China-Syria Bilateral Business Councils (since March 2014). He is general secretary of the Damascus Chamber of Commerce, (since December 2014) and Chairman of the Syrian Metal and Steel Council (since December 2015). Originally listed on 24/05/2011. Listed on: 27/01/2015 Last Updated: 01/06/2016 Group ID: 11933.
    1. MAKHLOUF, Ihab
      DOB:       21/01/1973. POB: Damascus a.k.a: (1) MAKHLOUF, Ehab (2) MAKHLOUF, Iehab Passport Details: N002848852 Position: Vice President of Syriatel. Leading businessman operating in Syria with interests including Ramak Construction Co and Syrian International Private University for Science and Technology. An influential member of the Maklouf family and closely connected to the Assad family. Cousin of President Bashar al-Assad. Listed on: 24/05/2011 Last Updated: 31/05/2013 Group ID: 11937.
    2. QADDUR, Khalid
      a.k.a:       (1) KADDOUR, Khaled (2) KADDOUR, Khalid (3) QADDOUR,
      Khaled (4) QADDOUR, Khalid (5) QADDUR, Khaled (6) QADOUR,
      Khaled (7) QADOUR, Khalid       Other Information: Leading businessman, operating in Syria with interests and/or activities in the telecommunications, oil and plastic industry sectors. Associate of close to Maher al-Assad. Originally listed on 24/06/2011. Listed on: 27/01/2015 Last Updated: 01/06/2016 Group ID: 12015.
    3. AL-QUWATLY, Ra’if
      DOB:       03/02/1967 POB: Damascus) a.k.a: (1) AL-KOUATLY, Raeef (2) AL- QUWATLI, Ri’af Other Information: Business associate of Maher Al-Assad and responsible for managing some of his business interests and providing funding to the regime. Listed on: 24/06/2011 Last Updated: 01/06/2016 Group ID: 12016.
    4. MAKHLOUF, Mohammed
      DOB:       19/10/1932. POB: Latakia, Syria a.k.a (1) RAMI, Abu Other Information: Leading businessman operating in Syria with interests in the General Organisation of Tobacco and the oil and gas, arms and banking sectors. Influential member of the Makhlouf family, business associate and father of Rami, Ihab and Iyad Makhlouf. Associated with the Assad family and maternal uncle of Bashar and Mahir al-Assad. Close associate and maternal uncle of Bashar and Mahir al-Assad. Business associate and father of Rami, Ihab and Iyad Makhlouf. Also referred to as Abu Rami. Listed on: 02/08/2011 Last Updated: 01/06/2016 Group ID: 12022.
    5. JABIR, Ayman
      POB:       Latakia a.k.a: JABER, Aiman Other Information: Leading Syrian

      businessman, operating in Syria involved in steel, media, consumable goods and oil sectors, including trading in these goods. Close to key figures of the Syrian regime such as Maher al-Assad and Rami Makhlouf. He has also provided support to the regime by facilitating the importation of oil from Overseas Petroleum Trading to Syria through his company El Jazireh. Financial interests in a number of companies and entities in Syria, in particular AL Jazira (aka Al Jazerra, El Jazireh). Dunia TV , and Sama Satelite Channel. His company Al Jazira, has facilitated the importation of oil from Overseas Petroleum Trading to Syria. Originally listed on 02/08/2011. Listed on: 27/01/2015 Last Updated: 01/06/2016 Group ID: 12023.

    6. DOUBA, Ali
      DOB: –/–/1933. POB: Karfis, Syria Other Information: Responsible for killings in Hama in 1980.Has been called back to Damascus as special advisor to President Bashar Al-Assad. Listed on: 24/08/2011 Last Updated: 01/06/2016 Group ID: 12046.
      1. HASSAN Samir
        Other Information:         Leading businessman operating in Syria, with interests and/or activities in multiple sectors of Syria’s economy. He holds interests in and/or has significant influence in the Amir Group and Cham Holdings two conglomerates with interests in the real estate, tourism, transport and finance sectors. He is associated with Rami Makhlouf and Issam Ambouba. He is a prominent businessman. Since March 2014, he has held the position of Vice Chairman for Russia of the Bilateral Business Councils. Listed on: 24/08/2011 Last Updated: 01/06/2016 Group ID: 12053.
      2. AL-JLEILATI Mohammad
        Title:         Dr DOB: –/–/1945. POB: Damascus a.k.a: (1) AL-JLEILATI,
        Mohamed (2) AL-JLEILATI, Mohammed (3) AL-JLEILATI, Muhammad         Position: Former Minister of Finance Other Information: Former Minister of Finance, in office until 9 February 2013 Listed on: 02/12/2011 Last Updated: 01/06/2016 Group ID: 12412.
      3. SUWAID Joseph
        DOB:         –/–/1958. POB: Damascus a.k.a: (1) SUWAID, Josef (2) SWAID,
        Josef (3) SWAID, Joseph (4) SWEID, Joseph, Jergi (5) SWEID, Joseph,
        Jirgi         Position:         Minister of State Other Information: Former Minister of State, in office until at least 21 January 2014 Listed on: 26/03/2012 Last Updated: 01/06/2016 Group ID: 12638.
      4. FARZAT Hussein Mahmoud
        DOB:         –/–/1957. POB: Hama a.k.a: (1) FARZAT, Hussain, Mahmoud (2) FARZAT, Hussein, Mahmud Position: Minister of State Other Information: Former Minister of State in office until at least 2014 Listed on: 26/03/2012 Last Updated: 01/06/2016 Group ID: 12640.
      5. SABOUNI Emad Abdul-Ghani
        Title: Dr DOB:         –/–/1964. POB: Damascus a.k.a: AL SABUNI, Imad, Abdul,
        Ghani         Position: Minister for Telecommunications and Technology Other Information: Former Minister of Telecommunications and Technology, in office until at least April 2014. Listed on: 28/02/2012 Last Updated: 01/06/2016 Group ID: 12506.
      6. MAHMOUD Adnan Hassan
        Title:         Dr DOB: –/–/1966. POB: Tartous Other Information: Former Minister of Information Listed on: 26/09/2011 Last Updated: 01/06/2016 Group ID: 12150.
      7. AL-AQQAD Hashim Anwar
        DOB:         –/–/1961. POB: Mohagirine, Syria a.k.a: (1) AKKAD, Hashem (2) AKKAD, Hashim (3) AQQAD, Hashem Position: Chairman of the Akkad Group of companies, that operate in multiple sectors of the Syrian economy, including oil and gas. Other Information: Leading businessman operating in Syria, with interests and/or activities in multiple sectors of Syria’s economy. He holds interests in and/or has significant influence in Anwar Akkad Sons Group (AASG) and its subsidiary United Oil. AASG has interests in sectors such as oil, gas, chemicals, insurance, industrial machinery, real estate, tourism, exhibitions, contracting, and medical equipment. Hashim Anwar al-Aqqad also worked as a member of the Syrian Parliament as recently as 2012. Listed on: 23/07/2014 Last Updated: 01/06/2016 Group ID: 13023.
        1. ABDULKARIM, Wael
          a.k.a:           AL KARIM, Wael Address: (1) Al Karim for Trade and Industry, PO Box 111, Damascus, Syria, 5797. (2) Pangates International Corp Ltd, PO Box Sharjah Airport International Free zone, United Arab Emirates. Position: Managing Director of Pangates International Corp Ltd and also holds a senior position in the Al Karim Group, which is Pangates’ parent company Other Information: Leading businessman operating in Syria in the oil, chemicals and manufacturing industries. Specifically, he represents Abdulkarim Group, a.k.a. Al Karim Group/Alkarim for Trade and Industry/Al Karim Trading and Industry/Al Karim for Trade and Industry. Listed on: 09/03/2015 Last Updated: 01/06/2016 Group ID: 13230.
        2. HASWANI, George
          a.k.a:           (1) AL HASAWANI, George (2) HASAWANI, George (3) HESWANI,
          George           Address: Damascus Province, Yabroud, Al Jalaa St., Syria. Other Information: Leading businessman operating in Syria, with interest and/or activities in the engineering, construction and oil and gas sectors. Holds interests in and/or has influence in a number of companies in Syria in particular HESCO Engineering and Construction Company. Facilitates deals for the purchase of oil from ISIL by the Syrian regime. Prominent Syrian businessman Co-founder of HESCO Engineering and Construction Company. Listed on: 09/03/2015 Last Updated: 01/06/2016 Group ID: 13232. 

Links:

HMT Notice

Council Implementing Regulation (EU) No 2016/840


Filed under: EU Updates, HMT Updates, Sanctions Lists, Syrian Sanctions
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June 3, 2016: HK SFC AML/CFT Circular updates CAR sanctions

June 7, 2016, 7:51 am
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May 27, 2016: HK SFC provides UN Yemen, Central African Republic updates

June 8, 2016, 6:34 am
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The Hong Kong Securities and Futures Commission announced in their AML/CFT Circular the passage of a new regulation for sanctions against the Central African Republic (CAR) and an amendment to the sanctions regulations for Yemen.

Links:

HK Securities and Futures Commission Notice

HK Securities and Futures Commission Circular

CAR Regulation

Yemen Amendment Regulation


Filed under: Central African Republic sanctions, HK Securities and Futures Commission, Sanctions Regulations, UN Updates, Yemen sanctions
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