Iran: Council extends by one year sanctions responding to serious human rights violation

On 12 April 2018, the Council extended until 13 April 2019 its restrictive measures responding to serious human rights violations in Iran. These measures consist of:

• a travel ban and an asset freeze against 82 people and one entity.
• a ban on exports to Iran of equipment which might be used for internal repression and of equipment for monitoring telecommunications.

These measures were first put in place in 2011. The legal acts will be published in the Official Journal of 13 April 2018.  

Link:

EU Notice

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CAATSA (the Countering America’s Adversaries Through Sanctions Act) passed in 2016 modified two Ukraine-related laws, UFSA & SSIDES. UFSA’s secondary sanctions on foreign financial institutions (FFI) that deal with Russia program SDNs under EOs 13660-13662 and future EOs were made mandatory, while CAATSA added a whole new sanction that levied mandatory sanctions on persons under IEEPA authorities. 

Mr. Watchlist wrote about this here on one of our partner’s blogs… hope you find it interesting.

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Press Releases

Link:

HKMA Alert

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Circular to Licensed Corporations and Associated Entities 

Anti-Money Laundering / Counter-Terrorist Financing

Early Alert on United Nations Sanctions 

The sanctions committee of the United Nations Security Council (“UNSC”) which administers the sanctions regime for ISIL (Da’esh) and Al-Qaida amended the entry of one individual in its sanctions list Note 1 on 10 April 2018.  Please refer to the relevant press release issued by the UNSC in Attachment 1.

Licensed corporations (“LCs”) and associated entities (“AEs”) should update their databases for sanctions screening of customers and payments accordingly.  LCs and AEs are reminded to refer to our circular on United Nations Sanctions issued on 7 February 2018 Note 2 which sets out our expectations on actions that LCs and AEs should take regarding sanctions imposed by the UNSC. 

Should you have any queries regarding the contents of this circular, please contact Ms Kiki Wong on 2231 1569.

Intermediaries Supervision Department
Intermediaries Division
Securities and Futures Commission

Links:

HK SFC Notice

HK SFC Circular

UN Web Notice

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On April 12th, Swiss authorities amended the following counter-terrorism sanctions listing:

SSID: 10-19042 Foreign identifier: TI.O.4.01. Name: Mohammed Omar Ghulam Nabi Title: Mullah DOB: a) 1966 (approximately) b) 1960 c) 1953 POB: a) Naw Deh village, Deh Rawud District, Uruzgan Province, Afghanistan b) Noori village, Maiwand District, Kandahar Province, Afghanistan Nationality: Afghanistan

Justification: Leader of the Faithful (‘Amir ul-Mumineen’), Afghanistan. Relation: Brother in law of Ahmad Jan Akhundzada Shukoor Akhundzada (TI.A.109.01., SSID 10-18174) Other information: Father’s name is Ghulam Nabi, also known as Mullah Musafir. Left eye missing. Brother-in-law of Ahmad Jan Akhundzada Shukoor Akhundzada (TI.A.109.01SSID 10-18174). Believed to be in Afghanistan/Pakistan border area. Belongs to Hotak tribe. Review pursuant to Security Council resolution 1822 (2008) was concluded on 27 Jul 2010. Reportedly deceased as of Apr 20132013. INTERPOL-UN Security Council Special Notice available. Modifications: Amended on 22 Jan 2014, 7 Sep 2016, 10 Apr 2018

Links:

FINMA Notice

Data files of updates – PDF, XML

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On April 12th, Canadian regulators implemented the changes to the following individual designation: 

TAi.004 Name: 1: MOHAMMED 2: OMAR 3: GHULAM NABI 4: na
Name (original script): محمد عمر غلام نبی
Title: Mullah Designation: Leader of the Faithful (‘Amir ul-Mumineen’), AfghanistanDOB: a) Approximately 1966 b) 1960 c) 1953 POB: a) Naw Deh village, Deh Rawud District, Uruzgan Province, Afghanistan b) Maiwand District, Kandahar Province, Afghanistan Good quality a.k.a.: na Low quality a.k.a.: na Nationality: AfghanistanPassport no: na National identification no: na Address: na Listed on: 31 Jan. 200112 Apr. 2000 (amended on 3 Sep. 2003, 21 Sep. 2007, 29 Nov. 2011, 31 Dec. 2013, 7 Sep. 2016) Other information: Father’s name is Ghulam Nabi, also known as Mullah Musafir.  Left eye missing. Brother-in-law of Ahmad Jan Akhundzada Shukoor Akhundzada (TAi.109). Believed to be in Afghanistan/Pakistan border area. Belongs to Hotak tribe. Review pursuant to Security Council resolution 1822 (2008) was concluded on 27 Jul. 2010.  Reportedly deceased as of April 2013.  INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/notice/search/un/1427394.

made by the United Nations 1988 Committee, which administers sanctions on the Taliban.

Links:

OSFI Notice

UN Notice

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On April 16th, Her Majesy’s Treasury (HMT) implemented Commission Implementing Regulation (EU) No 2018/566 by amending the following Democratic Republic of the Congo listing:

MUPOMPA Alex Kande

DOB: 23/09/1950. POB: Katanga, DRC a.k.a: (1) KANDE-MUPOMPA (2) MUPOMBA, Alexandre, Kande Nationality: DRC and Belgian nationalities Passport Details: DRC passport OP 0024910 (valid 21/03/2016 – expiry 20/03/2021) Address: Messidorlaan 217/25, 1180 Uccle, Belgium. Position: Governor of Kasai Central Other Information: EU listing. Former Governor of Kasai Central Listed on: 30/05/2017 Last Updated: 30/05/2017 16/04/2018 Group ID: 13461.

Links:

HMT Notice

Commission Implementing Regulation (EU) No 2018/566

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Last Friday, Her Majesty’s Treasury (HMT) implemented Council Implementing Regulation (EU) No 2018/602 By adding the following 4 persons to the sanctions against North Korea:

1. DJANG Tcheul Hy

DOB: 11/05/1950. POB: Kangwon Other Information: Annex XV. EU listing. Not UN. DJANG Tcheul Hy has been involved together with her husband KIM Yong Nam, her son KIM Su Gwang and her daughter-in-law KIM Kyong Hui in a pattern of deceptive financial practices which could contribute to the DPRK’s nuclear- related, ballistic-missile-related or other weapons of mass destruction-related programmes. She was the owner of several bank accounts in the Union which were opened by her son KIM Su Gwang in her name. She was also involved in several bank transfers from accounts from her daughter-in-law KIM Kyong Hui to bank accounts outside the Union. Listed on: 20/04/2018 Last Updated: 20/04/2018 Group ID: 13663.

2. KIM Kyong Hui

DOB: 06/05/1981. POB: Pyongyang, DPRK Other Information: Annex XV. EU listing. Not UN. KIM Kyong Hui has been involved together with her husband KIM Su Gwang, her father-in-law KIM Yong Nam and her mother-in-law DJANG Tcheul Hy in a pattern of deceptive financial practices which could contribute to the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes. She received several bank transfers from her husband KIM Su Gwang and fatherin-law KIM Yong Nam, and transferred money to accounts outside the Union in her name or the name of her motherin-law, DJANG Tcheul Hy. Listed on: 20/04/2018 Last Updated: 20/04/2018 Group ID: 13665.

3. KIM Su Gwang

DOB: 18/08/1976. POB: Pyongyang, DPRK a.k.a: (1) KIM, Son-Kwang (2) KIM, Sou-Gwang (3) KIM, Soukwang (4) KIM, Sou-Kwang (5) KIM, Su-

Kwang Position: Diplomat, DPRK Embassy, Belarus Other Information: Annex XV. EU listing. Not UN. KIM Su Gwang has been identified by the Panel of Experts as an agent of the Reconnaissance General Bureau, an entity which has been designated by the United Nations. He and his father KIM Yong Nam have been identified by the Panel of Experts as engaging in a pattern of deceptive financial practices which could contribute to the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes. KIM Su Gwang has opened multiple bank accounts in several Member States, including under family members’ names. He has been involved in various large bank transfers to bank accounts in the Union or to accounts outside the Union while working as a diplomat, including to accounts in the name of his spouse KIM Kyong Hui. Listed on: 20/04/2018 Last Updated: 20/04/2018 Group ID: 13664.

4. KIM Yong Nam

DOB: 02/12/1947. POB: Sinuju, DPRK a.k.a: (1) KIM, Yong-Nam (2) KIM, Young- Gon (3) KIM, Young-Nam Other Information: Annex XV. EU listing. Not UN. KIM Yong Nam has been identified by the Panel of Experts as an agent of the Reconnaissance General Bureau, an entity which has been designated by the United Nations. He and his son KIM Su Gwang have been identified by the Panel of Experts as engaging in a pattern of deceptive financial practices which could contribute to the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes. KIM Yong Nam has opened various current and savings accounts in the Union and has been involved in various large bank transfers to bank accounts in the Union or to accounts outside the Union while working as a diplomat, including to accounts in the name of his son KIM Su Gwang and daughter-in-law KIM Kyong Hui. Listed on: 20/04/2018 Last Updated: 20/04/2018 Group ID: 13662.

And the EU issued the following press release:

North Korea: EU adds four persons involved in financing of nuclear programme to sanctions list

The Council added four persons to the list of those subject to the restrictive measures against the Democratic People’s Republic of Korea (DPRK). These restrictive measures consist of a travel ban and an asset freeze. The four individuals have been involved in deceptive financial practices which are suspected of contributing to the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes.

The EU’s sanctions regime against the DPRK is its toughest on any country. These sanctions were adopted in response to the DPRK’s nuclear weapon and ballistic missile development activities, which are in breach of numerous UNSC resolutions. The EU not only transposes the sanctions imposed by the UN but also has its own autonomous sanctions regime on the DPRK, which complements and reinforces the sanctions adopted by the UN. The additional listings adopted today are part of the EU’s autonomous sanctions regime against the DPRK.

The decision brings the total number of persons listed autonomously by the EU to 59. In addition, the EU has frozen the assets of 9 entities as part of its own sanctions regime. It has also transposed all relevant UN Security Council resolutions, which impose sanctions on 80 persons and 75 entities currently listed by the UN.

EU foreign ministers discussed the situation on the Korean peninsula with the South Korean Foreign Minister, Kang Kyung-wha, on 19 March 2018, in light of the recent announcements made by the DPRK’s leadership and looking ahead to the summit between Kim Jong-un and South Korean President Moon Jae-in scheduled for April and the announced meeting between Kim Jong-un and US President Donald Trump. They welcomed South Korea’s efforts to de-escalate tensions on the peninsula and improve intra-Korean relations, and to create the conditions needed to work towards a diplomatic solution aimed at the complete, verifiable and irreversible denuclearisation of the Korean Peninsula.

The legal acts were adopted by written procedure. They include the names and specific reasons for listing and will be published in the Official Journal of 20 April 2018.

Links:

HMT Notice

Council Implementing Regulation (EU) No 2018/602

EU Press Release

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Last Tuesday, Australian regulators implemented the following amendment: 

TAi.004 Name: 1: MOHAMMED 2: OMAR 3: GHULAM NABI 4: na 

 محمد عمر غلام نبی :(script original (Name

Title: Mullah Designation: Leader of the Faithful (‘Amir ul-Mumineen’), 

Afghanistan DOB: a) Approximately 1966 b) 1960 c) 1953 POB: a) Naw Deh village, 

Deh Rawud District, Uruzgan Province, Afghanistan b) Maiwand District, Kandahar 

Province, Afghanistan Good quality a.k.a.: na Low quality 

a.k.a.: na Nationality: Afghanistan Passport no: na National identification 

no: na Address: na Listed on: 31 Jan. 2001 12 Apr. 2000 ( amended on 3 Sep. 2003, 21 

Sep. 2007, 29 Nov. 2011, 31 Dec. 2013, 7 Sep. 2016 ) Other information: Father’s 

name is Ghulam Nabi, also known as Mullah Musafir. Left eye missing. Brother-in-law 

of Ahmad Jan Akhundzada Shukoor Akhundzada (TAi.109). Believed to be in 

Afghanistan/Pakistan border area. Belongs to Hotak tribe. Review pursuant to Security 

Council resolution 1822 (2008) was concluded on 27 Jul. 2010. Reportedly deceased as 

of April 2013. INTERPOL-UN Security Council Special Notice web link: 

https://www.interpol.int/en/notice/search/un/1427394 click here

made by the United Nations 1988 (Taliban) Sanctions Commitee.

Link:

UN Notice

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Today, OFAC issued a new General License for the Ukraine/Russia-related sanctions program. General License 14 authorizes transactions that are “ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements, including the importation of goods, services, or technology into the United States” related to United Company RUSAL PLC and its 50 Percent Rule holdings for 6 more months (till October 23rd). Turns out UC Rusal has a US subsidiary (which my firm had already authorized).

Additionally, General License 12 has been replaced with 12A, which extends the deadline for other wind-down operations until June 5th (basically, an extra month).

OFAC also issued the following FAQs:

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575. Why is OFAC issuing General License 14, and what new activity does it authorize?

The purpose of General License 14 is to allow United Company RUSAL PLC (RUSAL) or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest, to continue maintenance or wind down activities until October 23, 2018. Although all funds blocked prior to 12:01 a.m. eastern daylight time, April 23, 2018 remain blocked, the general license authorizes the use of these blocked funds for the maintenance and wind down activities described in General License 14. In addition, U.S. persons are not required to block transactions authorized by General License 14 that occur on or after April 23, 2018, except for transactions involving blocked persons other than RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest. For a discussion of the relationship between General License 14 and foreign persons, please see FAQs 579 and 580. 

[04-23-2018]

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576. Under what circumstances can OFAC give further sanctions relief to RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest?

Consistent with OFAC regulations, parties may be removed by demonstrating a change in the circumstances that led to their designation. In the case of RUSAL, absent other adverse information and consistent with the facts and circumstances of any petition for delisting, the path for the United States to provide sanctions relief is through divestment and relinquishment of control of RUSAL by Oleg Deripaska. 

[04-23-2018]

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577. I am a U.S. person holding accounts for or other property of RUSAL or another entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest. Does General License 14 allow me to unblock this property?

No. All accounts or other property of RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest blocked as of April 23, 2018 remain blocked, except for the use in maintenance and wind-down activities described in General License 14. U.S. persons, however, may engage in transactions authorized by General License 14 that occur on or after April 23, 2018 without blocking payments associated with such transactions, except for transactions involving blocked persons other than RUSAL (including any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest).

[04-23-2018]

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578. How is General License 12A different from General License 12?

General License 12A now reflects the authorization in General License 14. Specifically, U.S. persons are not required to place into a blocked account payments to or for RUSAL, or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest, for activities authorized by General License 14. Activities necessary to the maintenance or wind down of operations or existing contracts of RUSAL and any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest, are authorized pursuant to General License 14 through October 23, 2018.

[04-23-2018]

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579. Will foreign persons be subject to sanctions under CAATSA for engaging in activity with RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest?

As described in FAQs 542, 545, and 574, a transaction will not be considered “significant” for the purposes of a sanctions determination under section 10 of SSIDES, as amended by section 228 of CAATSA, and section 5 of UFSA, as amended by section 226 of CAATSA, if U.S. persons would not require specific licenses from OFAC to participate in such a transaction. Therefore, activity authorized by General License 14, and occurring within the time period authorized by General License 14, would not be considered “significant” for the purposes of a sanctions determination under section 10 of SSIDES, as amended by CAATSA, or section 5 of UFSA, as amended by CAATSA.

[04-23-2018]

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580. I am a foreign person that seeks to pay RUSAL or another entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest for goods or services connected with maintenance or wind-down activities authorized by General License 14. Am I required to deposit payment into a blocked account at a U.S. financial institution in order for my payment to not be considered “significant” for purposes of section 10 of SSIDES, as amended by section 228 of CAATSA, or section 5 of UFSA, as amended by section 226 of CAATSA? 

No. U.S. persons may engage in activities authorized by General License 14 that occur on or after April 23, 2018, except for activities involving blocked persons other than RUSAL (or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest) without making associated payments into a blocked account. Similarly, foreign persons may engage in activities that would be authorized by General License 14 if engaged in by a U.S. person without making associated payments into a blocked account. 

[04-23-2018]

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581. I am a U.S. person that seeks to supply goods to RUSAL. Am I permitted to export those goods from the United States to RUSAL pursuant to General License 14?

Yes. General License 14 does not restrict exports to RUSAL (or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest), provided that the activity is for maintenance or wind down and consistent with the requirements of other federal agencies.

[04-23-2018]

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And Treasury issued the following press release:

Nice, touch, by the way – the Recent Actions page now shows links to related Press Releases.

Links:

OFAC Notice

Ukaine/Russia Related General Licenses – 12A, 14

New FAQs

Treasury Press Release

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On April 13th, Her Majesty’s Treasury (HMT) implemented Council Implementing Regulation (EU) No 2018/565 by amending the following individual: 

1. ABBASZADEH-MESHKINI Mahmoud

Position: Secretary of Advisor to the Human Right Council Other Information: Former Secretary of the Human Right Council. Former Governor of Ilam Province. Former Interior Ministry’s political director. Listed on: 12/10/2011 Last Updated: 13/04/2017 13/04/2018 Group ID: 12174.

2. AHMADI-MOQADDAM Esmail

DOB: –/–/1961. POB: Tehran, Iran Position: Senior Advisor for Security Affairs to the Chief of the Armed Forces General Staff Other Information: Former Senior Advisor for Security Affairs to the Chief of the Armed Forces General Staff Former Chief of Iran’s National Police until early 2015 Listed on: 14/04/2011 Last Updated: 13/04/2016 13/04/2018 Group ID: 11583.

3. AKBARSHAHI Ali-Reza

Position: Head of the Railway Police Director-General of Iran’s Drug Control Headquarters (aka Anti-Narcotics Headquarters) Other Information: Former Director-General of Iran’s Drug Control Headquarters (aka Anti-Narcotics Headquarters). Former Commander of Tehran Police Listed on: 12/10/2011 Last Updated: 13/04/2016 13/04/2018 Group ID: 12175.

4. ARAGHI Abdollah

a.k.a: ERAGHI, Abdollah Position: Deputy Head of the IRGC’s Ground Forces Other Information: Former Deputy Head of the IRGC’s Ground Forces Listed on: 14/04/2011 Last Updated: 12/05/2011 13/04/2018 Group ID: 11779.

5. AVAEE Seyyed Ali-Reza

a.k.a: AVAEE, Seyyed, Alireza Position: Director of the special investigations office Minister of Justice Other Information: Former Director of the special investigations office. Until July 2016 deputy Minister of Interior and head of the Public register. Advisor to the Disciplinary Court for Judges since April 2014. Former President of Tehran Judiciary. Listed on: 12/10/2011 Last Updated: 13/04/2017 13/04/2018 Group ID: 12177.

6. BAKHTIARI Seyyed Morteza

DOB: –/–/1952. POB: Mashad, Iran Position: Official of the Special Clerical Tribunal Deputy custodian of Imam Reza shrine. Other Information: Former Official of the Special Clerical Tribunal. Former Minister of Justice from 2009 to 2013 Listed on: 12/10/2011 Last Updated: 13/04/2016 13/04/2018 Group ID: 12200.

7. FAHRADI Ali

Position: Deputy head of Inspectorate of Legal Affairs and Public Inspection of the Ministry of Justice of Tehran. Prosecutor of Karaj Other Information: Former Prosecutor of Karaj Listed on: 29/03/2012 Last Updated: 13/04/2017 13/04/2018 Group ID: 12657.

8. HABIBI Mohammad Reza

Position: Head of the Ministry of Justice Office in Yazd Other Information: Former Deputy Prosecutor of Isfahan. Likely to be currently in a process of reassignment to another function. Listed on: 12/10/2011 Last Updated: 13/04/2017 13/04/2018 Group ID: 12181.

9. HADDAD Hassan

a.k.a: ZAREH DEHNAVI, Hassan Position: Deputy Safety Officer of Teheran Revolutionary Court Other Information: Former Deputy Safety Officer of Teheran Revolutionary Court. Former Judge, Tehran Revolutionary Court, branch 26. Listed on: 14/04/2011 Last Updated: 13/04/2016 13/04/2018 Group ID: 11792.

10. HOSSEINI Mohammad

Title: Dr DOB: –/–/1961. POB: Rafsanjan, Kerman a.k.a: (1) HOSSEYNI, Sayyed, Mohammad (2) HOSSEYNI, Sayyid, Mohammad (3) HOSSEYNI, Seyed, Mohammad (4) HOSSEYNI, Seyyed, Mohammad Position: Advisor to Former President Mahmoud Ahmadinejad Other Information: Former Minister of Culture and Islamic Guidance. Ex-IRGC. Listed on: 12/10/2011 Last Updated: 14/04/2014 13/04/2018 Group ID: 12201.

11. JOKAR Mohammad Saleh

Position: Parliamentary Deputy for Yazd Province. Deputy for Parliamentary Affairs of the Revolutionary Guards. Other Information: Former Parliamentary Deputy for Yazd Province. Former Commander of Student Basij Forces Listed on: 12/10/2011 Last Updated: 14/04/2014 13/04/2018 Group ID: 12186.

12. MAHSOULI Sadeq

DOB: (1) –/–/1959. (2) –/–/1960. POB: Oroumieh, Iran a.k.a: MAHSULI,

Sadeq Position: Advisor to Former President Mahmoud Ahmadinejad and current member of the Expediency Council and Deputy Chief of the Perseverance Front. Other Information: Former Minister of Interior until Aug 2009. Minister of Welfare and Social Security between 2009 and 2011. Listed on: 12/10/2011 Last Updated: 12/10/2011 13/04/2018 Group ID: 12189.

13. MOHSENI-EJEI Gholam-Hossein

DOB: –/–/1956. POB: Ejiyeh, Iran Position: Member of the Expediency Council. Prosecutor General of Iran since Sept 2009 and Deputy Head and spokesman of the Judiciary Other Information: Former Intelligence minister during the 2009 elections. Listed on: 14/04/2011 Last Updated: 12/05/2011 13/04/2018 Group ID: 11797.

14. MORTAZAVI Seyyed Solat

DOB: –/–/1967. POB: Farsan Tchar Mahal-o-Bakhtiari (South), Iran Position: Mayor of the second largest city of Iran, Mashad Other Information: Former Mayor of the second largest city of Iran, Mashad. Former Deputy Interior Minister for Political Affairs Listed on: 29/03/2012 Last Updated: 13/04/2016 13/04/2018 Group ID: 12653.

15. NAQDI Mohammad-Reza

DOB: –/–/1952. POB: Najaf, Iraq Position: Commander of the Basij Deputy Chief of the IRGC for cultural and Social affairs. Other Information: Former Commander of the Basij. Listed on: 14/04/2011 Last Updated: 12/05/2011 13/04/2018 Group ID: 11784.

16. OMIDI Mehrdad

a.k.a: OMIDI Reza Position: Head of the Intelligence Services within the Iranian Police Head of section VI of the police, investigation department. Other Information: Former Head of the Intelligence Services within the Iranian Police. Former Head of Computer Crimes Unit of the Iranian Police Listed on: 12/10/2011 Last Updated: 13/04/2016 13/04/2018 Group ID: 12191.

17. RADAN Ahmad-Reza

DOB: –/–/1963. POB: Isfahan, Iran Position: IRGC commander in charge of training Iraqi ‘anti-terrorist’ forces In Charge of the Centre for Strategic Studies of the Iranian Law Enforcement Force Other Information: Formerly in charge of the Centre for Strategic Studies of the Iranian Law Enforcement Force. Former Head of the Police Strategic Studies Centre, Former Deputy Chief of Iran’s National Police until June 2014. Listed on: 14/04/2011 Last Updated: 13/04/2016 13/04/2018 Group ID: 11785.

18. RAJABZADEH Azizollah

Position: Commander of the Law Enforcement Forces in Greater Tehran. Head of Tehran Disaster Mitigation Organisation (TDMO). Other Information: Former Head of the Law Enforcement Forces in Greater Tehran. Former Head of Tehran Disaster Mitigation Organisation (TDMO). Former Head of Tehran Police (until Jan 2010). Listed on: 14/04/2011 Last Updated: 14/04/2014 13/04/2018 Group ID: 11786.

19. RAMEZANI Gholamhossein

Position: Commander of IRGC Intelligence Chief of the Intelligence of the Ministry of Defence since 2011. Other Information: Former Commander of IRGC Intelligence Listed on: 29/03/2012 Last Updated: 29/03/2012 13/04/2018 Group ID: 12659.

20. SAJEDI-NIA Hossein

Position: Head of Tehran Police Police Operations Deputy Commander. Other Information: Former Head of Tehran Police. Former Deputy Chief of Iran’s National Police responsible for Police Operations. Listed on: 14/04/2011 Last Updated: 12/05/2011 13/04/2018 Group ID: 11787.

21. SALARKIA Mahmoud

Position: Head of the Petrol and Transport commission of the City of Tehran Other Information: Former Head of the Petrol and Transport commission of the City of Tehran. Former Director of Tehran Football Club ‘Persepolis’. Former Deputy to the Prosecutor General of Tehran for Prison Affairs. Listed on: 12/10/2011 Last Updated: 13/04/2017 13/04/2018 Group ID: 12192.

22. SARAFRAZ Mohammad

Title: Dr DOB: –/–/1963. POB: Tehran a.k.a: SARAFRAZ, Haj-agha Address: Tehran. Position: Member of the Supreme Cyberspace Council Other Information: Former Member of the Supreme Cyberspace Council. Former president of the Islamic Republic of Iran Broadcasting (IRIB). Former Head of IRIB World Service and Press TV. DOB is approximate. Place of work – IRIB and PressTV HQ, Tehran. Listed on: 12/03/2013 Last Updated: 13/04/2017 13/04/2018 Group ID: 12852.

23. TAEB Hossein

Title: Hojjatoleslam DOB: –/–/1963. POB: Tehran, Iran a.k.a: (1) TAEB, Hassan (2) TAEB, Hosein (3) TAEB, Hussayn (4) TA’EB, Hossein Position: Deputy Commander for Intelligence of Iranian Revolutionary Guard Corps Head of IRGC Intelligence Other Information: Former Deputy Commander for Intelligence of Iranian Revolutionary Guard Corps. EU listing under Iran (human rights) and Syria. Listed on: 14/04/2011 Last Updated: 31/05/2013 13/04/2018 Group ID: 11788.

24. TALA Hossein

a.k.a: TALA, Hosseyn Position: Mayor of Eslamshahr. Other Information: Former Governor General (‘Farmandar’) of Tehran Province until Sept 2010. Former Iranian MP. Listed on: 12/10/2011 Last Updated: 13/04/2017 13/04/2018 Group ID: 12194.

25. TAMADDON Morteza

DOB: –/–/1959. POB: Shahr Kord-Isfahan a.k.a: TAMADON, Morteza Position: Board Member at Khajeh Nasireddin Tusi University of Technology Other Information: Former IRGC Governor General of Tehran Province. Former Head of Tehran provincial Public Security Council. Listed on: 12/10/2011 Last Updated: 14/04/2014 13/04/2018 Group ID: 12195.

26. YASAGHI Ali-Akbar

Position: Judge, Mashhad Revolutionary Court Judge of the Supreme Court and head of the 44th section. Deputy Chief Executive Officer of Setad-e Dieh Foundation. Other Information: Former Chief Judge, Mashhad Revolutionary Court Listed on: 14/04/2011 Last Updated: 12/05/2011 13/04/2018 Group ID: 11789.

27. ZANJIREI Mohammad-Ali

Position: Senior advisor to Deputy Head of Iran’s Prisons Organisation Other Information: Former Deputy Head of Iran’s Prisons Organisation Listed on: 14/04/2011 Last Updated: 12/05/2011 13/04/2018 Group ID: 11808.

28. ZEBHI Hossein

Position: Deputy to the Prosecutor General of Iran Judge of the Supreme Court. Other Information: Former Deputy to the Prosecutor General of Iran. Listed on: 12/10/2011 Last Updated: 12/10/2011 13/04/2018 Group ID: 12196.

and entity: 

CENTER TO INVESTIGATE ORGANIZED CRIME CYBER POLICE

a.k.a: (1) CYBER CRIME OFFICE (2) CYBER POLICE Address: Tehran, Iran. Other Information: The Iranian Cyber Police is a unit of the Islamic Republic of Iran Police, founded in January 2011, headed by Esmail Ahmadi-Moqaddam. Website: http://www.cyberpolice.ir Listed on: 12/03/2013 Last Updated: 12/03/2013 13/04/2018 Group ID: 12864.

Iran human rights sanctions listings:

Links:

HMT Notice

Council Implementing Regulation (EU) No 2018/565

Edited with BlogPad Pro

Link:

Treasury Press Release

Edited with BlogPad Pro

On Tuesday, Swiss authorities amended the following individual Iran sanctions listings:

SSID: 80-13066 Foreign identifier: 1. Name: Ahmadi-Moqaddam Esmail

DOB: 1961 POB: Tehran, Iran

Justification: Former Senior Advisor for Security Affairs to the Chief of the Armed Forces General Staff. Former Chief of Iran’s National Police from 2005 until early 2015. Forces under his command led brutal attacks on peaceful protests, and a violent night-time attack on the dormitories of Tehran University on 15 Jun 20092009. Currently head of Iran’s Headquarters in support of the Yemeni People. Modifications: Amended on 18 May 2016, 24 Apr 2018

SSID: 80-13076 Foreign identifier: 3. Name: Araghi Abdollah

Good quality a.k.a.: Eraghi Abdollah

Justification: Former Deputy Head of IRGC’s Ground Forces. He had a direct and personal responsibility in the crackdown of protests all through the Summer of 2009. Modifications: Amended on 24 Apr 2018

SSID: 80-13104 Foreign identifier: 9. Name: Naqdi Mohammad-Reza

DOB: 1952 (approximately) POB: Najaf, Iraq

Justification: Deputy Chief of the IRGC for cultural and social affairs. Former Commander of the Basij. As commander of the IRGC’s Basij Forces, Naqdi was responsible for or complicit in Basij abuses occurring in late 2009, including the violent response to the December 2009 Ashura Day protests, which resulted in up to 15 deaths and the arrests of hundreds of protesters. Prior to his appointment as commander of the Basij in October 2009, Naqdi was the head of the intelligence unit of the Basij responsible for interrogating those arrested during the post-election crackdown. Modifications: Amended on 24 Apr 2018

SSID: 80-13110 Foreign identifier: 10. Name: Radan Ahmad-Reza

DOB: 1963 POB: Isfahan, Iran

Justification: He isFormerly in charge of the Centre for Strategic Studies of the Iranian Law Enforcement Force, a body linked to the National Police. Former Head of the Police Strategic Studies Centre, former Deputy Chief of Iran’s National Police until Jun 2014. As Deputy Chief of National Police from 2008, Radan was responsible for beatings, murder, and arbitrary arrests and detentions against protestors that were committed by the police forces. Currently IRGC commander in charge of training Iraqi ‘anti-terrorist’ forces. Modifications: Amended on 12 May 2015, 18 May 2016, 24 Apr 2018

SSID: 80-13116 Foreign identifier: 11. Name: Rajabzadeh Azizollah

Justification: Former Head of Tehran Disaster Mitigation Organisation (TDMO). Former Head of Tehran Police (until January 2010). As Commander of the Law Enforcement Forces in the Greater Tehran, Azizollah Rajabzadeh is the highest ranking accused in the case of abuses in Kahrizak Detention CenterCentre. Modifications: Amended on 24 Apr 2018

SSID: 80-13120 Foreign identifier: 12. Name: Sajedi-Nia Hossein

Justification: Police Operations Deputy Commander. Former Head of Tehran Police, former Deputy Chief of Iran’s National Police responsible for Police Operations. He is in charge of coordinating, for the Ministry of Interior, repression operations in the Iranian capital. Modifications: Amended on 24 Apr 2018

SSID: 80-13124 Foreign identifier: 13. Name: Taeb Hossein

DOB: 1963 POB: Tehran

Justification: Head of IRGC Intelligence. Former Deputy IRGC commander for intelligence. Former Commander of the Basij until Oct 2009. Forces under his command participated in mass beatings, murders, detentions and tortures of peaceful protestors. Modifications: Amended on 12 May 2015, 24 Apr 2018

SSID: 80-13141 Foreign identifier: 16. Name: Haddad Hassan

Good quality a.k.a.: Zareh Dehnavi Hassan

Justification: Former Deputy Safety Officer of Teheran Revolutionary Court. Former Judge, Tehran Revolutionary Court, branch 26. He was in charge of the detainee cases related to the post-election crises and regularly threatened families of detainees in order to silence them. He has been instrumental in issuing detention orders to the Kahrizak Detention Centre. In Nov 2014, his role in the deaths of detainees was officially recognised by the Iranian authorities. Modifications: Amended on 12 May 2015, 18 May 2016, 24 Apr 2018

SSID: 80-13163 Foreign identifier: 21. Name: Mohseni-Ejei Gholam-Hossein

DOB: 1956 (approximately) POB: Ejiyeh

Justification: Member of the Expediency Council. Prosecutor General of Iran since Sep 2009 and Deputy Head and spokesman of the Judiciary, and formerJudiciary. Former Intelligence minister during the 2009 elections. While he was Intelligence minister during the 2009 election, intelligence agents under his command were responsible for detention, torture and extraction of false confessions under pressure from hundreds of activists, journalists, dissidents, and reformist politicians. In addition, political figures were coerced into making false confessions under unbearable interrogations, which included torture, abuse, blackmail, and the threatening of family members. Modifications: Amended on 12 May 2015, 24 Apr 2018

SSID: 80-13189 Foreign identifier: 26. Name: Sharifi Malek Adjar

Justification: Judge at the Supreme CourtCourt, head of the 43rd section. Former Head of East Azerbaidjan Judiciary. He was responsible for Sakineh Mohammadi-Ashtiani’s trial. Modifications: Amended on 18 May 2016, 24 Apr 2018

SSID: 80-13197 Foreign identifier: 28. Name: Yasaghi Ali-Akbar

Justification: Judge of the Supreme CourtCourt head of the 44th section. Deputy Chief Executive Officer of Setad-e Dieh Foundation. Former Chief Judge, Mashhad Revolutionary Court. Trials under his jurisdiction have been conducted summarily and inside closed session, without adherence to basic rights of the accused. As execution rulings were issued en masse, death sentences were issued without proper observance of fair hearing procedures. Modifications: Amended on 12 May 2015, 24 Apr 2018

SSID: 80-13213 Foreign identifier: 32. Name: Zanjirei Mohammad-Ali

Justification: AsSenior advisor to Head, and former Deputy Head of Iran’s Prisons Organisation, responsible for abuses and deprivation of rights in detention center. He ordered the transfer of many inmates into solitary confinement. Modifications: Amended on 24 Apr 2018

SSID: 80-13217 Foreign identifier: 33. Name: Abbaszadeh-Meshkini Mahmoud Justification: a) Advisor to the Human Right Council. Former Secretary of the Human Right Council. Former governor of Ilam Province. Former Interior Ministry’s political director. As Head of the Article 10 Committee of the Law on Activities of Political Parties and Groups he was in charge of authorising demonstrations and other public events and registering political parties. b) In 2010, he suspended the activities of two reformist political parties linked to Mousavi – the Islamic Iran Participation Front and the Islamic Revolution Mujahedeen Organisation. c) From 2009 onwards he has consistently and continuously prohibited all non-governmental gatherings, therefore denying a constitutional right to protest and leading to many arrests of peaceful demonstrators in contravention of the right to freedom of assembly. d) He also denied in 2009 the opposition a permit for a ceremony to mourn people killed in protests over the Presidential elections. Modifications: Amended on 2 May 2017, 24 Apr 2018

SSID: 80-13221 Foreign identifier: 34. Name: Akbarshahi Ali-Reza

Justification: Former Director-General of Iran’s Drug Control Headquarters (a.k.a. Anti- Narcotics Headquarters). Former Commander of Tehran Police. Under his leadership, the police force was responsible for the use of extrajudicial force on suspects during arrest and pre-trial detention. The Tehran police were also implicated in raids on Tehran university dorms in Jun 2009, when according to an Iranian Majlis commission, more than 100 students were injured by the police and BasijiBasiji. Currently head of the railway police. Modifications: Amended on 12 May 2015, 18 May 2016, 24 Apr 2018

SSID: 80-13229 Foreign identifier: 36. Name: Avaee Seyyed Ali-Reza

Good quality a.k.a.: Avaee Seyyed Alireza

Justification: Minister of Justice. Former Director of the special investigations office. Until Jul 2016 deputy Minister of Interior and head of the Public register. Advisor to the Disciplinary Court for Judges since Apr 2014. Former President of the Tehran Judiciary. As President of the Tehran Judiciary he has been responsible for human rights violations, arbitrary arrests, denials of prisoners’ rights and an increase in executions. Modifications: Amended on 12 May 2015, 2 May 2017, 24 Apr 2018

SSID: 80-13249 Foreign identifier: 40. Name: Habibi Mohammad Reza

Justification: Head of the Ministry of Justice office in Yazd. Former Deputy Prosecutor of Isfahan. Likely to be currently in a process of reassignment to another function. Complicit in proceedings denying defendants a fair trial – such as Abdollah Fathi executed in May 2011 after his right to be heard and mental health issues were ignored by Habibi during his trial in Mar 2010. He is, therefore, complicit in a grave violation of the right to due process, contributing to the excessive and increasing use of the death penalty and a sharp increase in executions since the beginning of 2011. Modifications: Amended on 12 May 2015, 18 May 2016, 2 May 2017, 24 Apr 2018

SSID: 80-13277 Foreign identifier: 45. Name: Jokar Mohammad Saleh

Justification: Deputy for Parliamentary Affairs of the Revolutionary Guards. From 2011 until 2016 parliamentary deputy for Yazd Province and Member of the parliamentary Committee for National Security and Foreign Policy. Former Commander of Student Basij Forces. In thisthe capacity of Commander of Student Basij Forces he was actively involved in suppressing protests in schools and universities and extra-judicial detention of activists and journalists. Modifications: Amended on 24 Apr 2018

SSID: 80-13292 Foreign identifier: 48. Name: Mahsouli Sadeq

DOB: a) 1959 b) 1960 POB: Oroumieh, Iran Good quality a.k.a.: Mahsuli Sadeq Justification: Advisor to Former President Mahmoud Ahmadinejad and current member of the Expediency Council Mahmoud Ahmadinejad and memberDeputy Chief of the Perseverance Front. Minister of Welfare and Social Security between 2009 and 2011. Minister of the Interior until Aug 2009. As Interior Minister, Mahsouli had authority over all police forces, interior ministry security agents, and plainclothes agents. The forces under his direction were responsible for attacks on the dormitories of Tehran University on 14 Jun 2009 and the torture of students in the basement of the Ministry (the notorious basement level 4). Other protestors were severely abused at the Kahrizak Detention Center, which was operated by police under Mahsouli’s control. Modifications: Amended on 12 May 2015, 24 Apr 2018

SSID: 80-13305 Foreign identifier: 50. Name: Omidi Mehrdad

Good quality a.k.a.: a) Reza Omidi b) Reza

Justification: Head of section VI of the police, investigation department. Former Head of the Intelligence Services within the Iranian Police. Former Head of the Computer Crimes Unit of the Iranian Police. He is responsible for thousands of investigations and indictments of reformists and political opponents using the Internet. He is thus responsible for grave human rights violations in the repression of persons who speak out in defence of their legitimate rights, including freedom of expression. Modifications: Amended on 18 May 2016, 24 Apr 2018

SSID: 80-13309 Foreign identifier: 51. Name: Salarkia Mahmoud

Justification: a) Former Head of the Petrol and Transport commission of the City of Tehran. Deputy to the Prosecutor-General of Tehran for Prison Affairs during the crackdown of 2009. b) As Deputy to the Prosecutor-General of Tehran for Prison Affairs he was directly responsible for many of the arrest warrants against innocent, peaceful protesters and activists. Many reports from human rights defenders show that virtually all those arrested are, on his instruction, held incommunicado without access to their lawyer or families, and without charge, for varying lengths of time, often in conditions amounting to enforced disappearance. Their families are often not notified of the arrest. Other information: Former director of Tehran Football Club “Persepolis” Modifications: Amended on 2 May 2017, 24 Apr 2018

SSID: 80-13317 Foreign identifier: 53. Name: Tala Hossein

Good quality a.k.a.: Tala Hosseyn

Justification: Mayor of Eslamshahr. Former Iranian MP. Former Governor-General (“Farmandar”) of Tehran Province until Sep 2010, he was responsible for the intervention of police forces and therefore for the repression of demonstrations. He received a prize in Dec 2010 for his role in the post-election repression. Modifications: Amended on 12 May 2015, 2 May 2017, 24 Apr 2018

SSID: 80-13322 Foreign identifier: 54. Name: Tamaddon Morteza

DOB: 1959 POB: Shahr Kord-Isfahan Good quality a.k.a.: Tamadon Morteza Justification: Former Head of Tehran provincial Public Security Council. Former IRGC Governor-General of Tehran Province. In his capacity as governor and head of Tehran provincial Public Security Council, he bears overall responsibility for all repressive activities undertaken by the IRGC in Tehran province, including cracking down on political protests since Jun 20092009. Currently board member at Khajeh Nasireddin Tusi University of Technology. Modifications: Amended on 12 May 2015, 24 Apr 2018

SSID: 80-13330 Foreign identifier: 55. Name: Zebhi Hossein

Justification: Judge of the Supreme Court. Former Deputy to the Prosecutor General of Iran. He is in charge of several judicial cases linked to the post-elections protests. Modifications: Amended on 24 Apr 2018

SSID: 80-13346 Foreign identifier: 59. Name: Bakhtiari Seyyed Morteza

DOB: 1952 POB: Mashad, Iran

Justification: Deputy custodian of Imam Reza shrine. Former Official of the Special Clerical Tribunal. Former Minister of Justice from 2009 to 2013. During his time as Minister of Justice, prison conditions within Iran fell well below accepted international standards, and there was widespread mistreatment of prisoners. In addition, he played a key role in threatening and harassing the Iranian diaspora by announcing the establishment of a special court to deal specifically with Iranians who live outside the country. He also oversaw a sharp increase in the number of executions in Iran, including secret executions not announced by the government, and executions for drug-related offences. Modifications: Amended on 12 May 2015, 18 May 2016, 24 Apr 2018

SSID: 80-13352 Foreign identifier: 60. Name: Hosseini Mohammad

Title: Dr DOB: 1961 POB: Rafsanjan, Kerman Good quality a.k.a.: a) Hosseyni Seyyed Mohammad b) Seyed c) Sayyed d) Sayyid

Justification: Advisor to Former President and current member of the Expediency Council Mahmoud AhmadinejadAhmadinejad and spokesperson for YEKTA hardline political faction. Former Minister of Culture and Islamic Guidance (2009-2013). Ex-IRGC, he was complicit in the repression of journalists. Modifications: Amended on 12 May 2015, 24 Apr 2018

SSID: 80-13407 Foreign identifier: 69. Name: Mortazavi Seyyed Solat

DOB: 1967 POB: Farsan, Tchar Mahal-o-Bakhtiari (South), Iran

Justification: MayorFormer mayor of the second largest city of Iran, Mashad, where public executions regularly happen. Former Deputy Interior Minister for Political Affairs. He was responsible for directing repression of persons who spoke up in defence of their legitimate rights, including freedom of expression. Later appointed as Head of the Iranian Election Committee for the parliamentarian elections in 2012 and for the presidential elections in 2013. Modifications: Amended on 12 May 2015, 18 May 2016, 24 Apr 2018

SSID: 80-13426 Foreign identifier: 73. Name: Fahradi Ali

Justification: Deputy head of Inspectorate of Legal Affairs and Public Inspection of the Ministry of Justice of Tehran. ProsecutorFormer prosecutor of Karaj. Responsible for grave violations of human rights, including prosecuting trials in which the death penalty is passed. There have been a high number of executions in Karaj region during his time as prosecutor. Modifications: Amended on 12 May 2015, 18 May 2016, 2 May 2017, 24 Apr 2018

SSID: 80-13434 Foreign identifier: 75. Name: Ramezani GholamhoseinGholamhossein Justification: SecuritySince 2011 Chief atof the Intelligence of the Ministry of Defence. Former ChiefDefence; from Nov 2009 to Mar 2011: Commander of Protection and Security atIntelligence of the IRGC untilPasdaran; from Mar 2012. Ex-Commander2008 to Nov 2009: Deputy Commander of Intelligence of the Pasdaran; from Apr 2006 to Mar 2008: Head of IRGCProtection and Intelligence until Oct 2009of the Pasdaran. Involved in the suppression of freedom of expression, including by being associated with those responsible for the arrests of bloggers/journalists in 2004, and reported to have had a role in the suppression of the post-election protests in 2009. Modifications: Amended on 12 May 2015, 24 Apr 2018

Links:

FINMA Notice

Data files of updates – PDF, XML

Edited with BlogPad Pro

On Tuesday, Swiss officials updated the following individual Yemen sanctions listing:

SSID: 85-29644 Foreign identifier: YEi.003 Name: Ali Abdullah Saleh

Sex: M DOB: a) 21 Mar 1945 b) 21 Mar 1946 c) 21 Mar 1942 d) 21 Mar 1947 POB: a) Bayt al-Ahmar, Sana’a Governorate, Yemen b) Sana’a, Yemen c) Sana’a, Sanhan, Al-Rib’ al- Sharqi Good quality a.k.a.: Ali Abdallah Salih Nationality: Yemen Identification document: a) Passport No. 00016161, Yemen b) ID card No. 01010744444, Yemen Justification: a) President of Yemen’s General People’s Congress party b) Former President of the Republic of Yemen c) Ali Abdullah Saleh was designated for sanctions on 7 Nov 2014 pursuant to paragraphs 11 and 15 of resolution 2140 (2014), as meeting the designation criteria set out in paragraphs 17 and 18 of the resolution. Other information: a) Ali Abdullah Saleh has engaged in acts that threaten the peace, security, or stability of Yemen, such as acts that obstruct the implementation of the agreement of 23 Nov 2011 between the Government of Yemen and those in opposition to it, which provides for a peaceful transition of power in Yemen, and acts that obstruct the political process in Yemen. b) Per the 23 Nov 2011 agreement backed by the Gulf Cooperation Council, Ali Abdullah Saleh stepped down as President of Yemen after more than 30 years. c) As of fall 2012, Ali Abdullah Saleh had reportedly become one of the primary supporters of violent Huthi actions in northern Yemen. d) Clashes in the south of Yemen in Feb 2013 were a result of the combined efforts of Saleh, AQAP and southern secessionist Ali Salim al-Bayd to cause trouble before the, 18 Mar 2013 National Dialogue Conference in Yemen. e) More recently, as of Sep 2014, Saleh has been destabilizing Yemen by using others to undermine the central government and create enough instability to threaten a coup. According to a Sep 2014 report by the United Nations Panel of Experts for Yemen, interlocutors alleged that Saleh supports violent actions of some Yemenis by providing them funds and political support, as well as ensuring that GPC members continue to contribute to the destabilization of Yemen through various means. f) The Sep 2014 United Nations Panel of Experts report on Yemen also states that allegations have been made that Ali Abdullah Saleh has been using Al-Qaida in the Arabian Peninsula (AQAP) operatives to conduct assassinations and attacks against military installations in order to weaken President Hadi and create discontent within the army and broader Yemeni population. g) Status: reportedly deceased. Modifications: Listed on 5 Dec 2014, amended on 23 Apr 2018

You’ll notice that Saleh has not been removed from the list, despite being “reportedly deceased.”

Links:

FINMA Notice

Data files of updates – PDF, XML

Edited with BlogPad Pro

On Tuesday, Swiss regulators amdended the following pairs of sanctions designations made under the Democratic Republic of the Congo (DRC) sanctions program:

SSID: 100-38167 Name: Mupompa Alex Kande

DOB: 23 Sep 1950 POB: Kananga, Congo DR Good quality a.k.a.: a) Alexandre Kande Mupomba b) Kande-Mupompa Address: Messidorlaan 217/25, 1180 Uccle, Belgium Nationality: a) Congo DR b) Belgium Identification document: Passport No. OP 0024910, Congo DR, Date of issue: 21 Mar 2016, Expiry date: 20 Mar 2021

Justification: a) As Governor of Kasai CentralCentral until Oct 2017, Alex Kande Mupompa is responsible for the ongoing disproportionate use of force, violent repression and extrajudicial killings committed by security forces and the PNC in Kasai Central from Aug 2016, including the alleged unlawful killings on the territory of Kamiuna Nsapu militia members and civilians in Mwanza Lomba, Kasai Central,Dibaya in Feb 2017. b) Alex Kande Mupompa was therefore involved in planning, directing, or committing acts that constitute serious human rights violations in DRC. Other information: a) DRC and Belgian nationalities. b) Former Governor of Kasai Central. Modifications: Listed on 21 Feb 2018, amended on 24 Apr 2018

SSID: 100-38190 Name: Mende Lambert

DOB: 11 Feb 1953 POB: Okolo, Congo DR Good quality a.k.a.: Lambert Mende Omalanga Nationality: Congo DR Identification document: Diplomatic passport No. DB0001939, Congo DR, Date of issue: 4 May 2017, Expiry date: 3 May 2022

Justification: a) As Communications and Media Minister since 2008, Lambert Mende is responsible for the repressive media policy applied in DRC, which breaches the right to freedom of expression and information and undermines a consensual and peaceful solution towards elections in DRC. On 12 Nov 2016, he adopted a decree limiting the possibility for foreign media outlets to broadcast in the DRC. b) In breach of the political agreement settled on 31 Dec 2016 between the presidential majority and opposition parties, broadcasts have not resumed forof a number of media outlets as at May 2017remained cut off for several months. c) In his capacity as Communications and Media Minister, Lambert Mende is therefore responsible for obstructing a consensual and peaceful solution towards elections in DRC, including by acts of violence, repression or inciting violence, or by undermining the rule of law. Other information: Minister of Communications and Media, and spokesperson of the Government. Modifications: Listed on 21 Feb 2018, amended on 24 Apr 2018

Links:

FINMA Notice

Data files of updates – PDF, XML

Edited with BlogPad Pro

Our Ref.: B10/21C 12 April 2018

The Chief Executive

All Stored Value Facility Licensees

Dear Sir/Madam,

Sanctions Screening Systems

I am writing to reiterate some important regulatory requirements by the Hong Kong Monetary Authority (HKMA) in relation to sanctions compliance. Stored value facility (SVF) licensees are reminded to put in place adequate measures which are appropriate to the nature and size of businesses, to meet their obligations under the Hong Kong’s financial sanctions regime. It is also the HKMA’s regulatory requirement on SVF licensees that sanctions screening should be conducted for new customers and payments as well as for existing customers whenever new designations are published1.

The adequacy of sanctions screening systems and controls is a supervisory priority for the HKMA, especially in the light of recent geopolitical developments. To test the effectiveness of the SVF sector in meeting sanctions obligations, we are planning to conduct thematic reviews on a number of SVF licensees in the coming months, taking into account the nature and size of their businesses. To assist SVF licensees in understanding and optimizing the performance of their screening systems, as well as preparing for the upcoming review, we are sharing key observations and good practices from a similar thematic review we have recently conducted in relation to the financial sanctions screening systems of Authorized Institutions (AIs).

While sanctions compliance policies and risk appetite may differ between SVF licensees and AIs, dependent on the particular business model, SVF licensees are encouraged to review the good practices provided at Annex and consider adopting such, as applicable, to help strengthen their ability to meet sanctions obligations.

If you have any questions on this circular, please contact Mr Alex Chow at 2878-8769 or Mr Dixon Lam at 2878-8721.

Yours faithfully,

Carmen Chu

Executive Director (Enforcement and AML)

Link:

HKMA Notice

Edited with BlogPad Pro

On April 12th, the Hong Kong Monetary Authority issued a memorandum relating the feedback from its recent review of Authorized Institutions’ (AI) sanctions screening. Here’s the meat of the feedback – the themes are the top-level bullets (e.g. 1, 2, 3), with the feedback in the subsidiary items (e.g. 1.2, 3.1):

1. AIs’ senior management should consider the risk of sanctions breaches and determine the appropriate level of sanctions screening to manage the risk for the AI

1.1 AIs should be able to demonstrate a proven methodology for determining system settings and performance, and which is consistent with compliance policies and risk appetite. This includes a thorough understanding of the risks, the types of customer the AI has and the geographic regions the customers are operating in. Most AIs as examined in the thematic review were able to articulate their respective choices of system configuration and settings to varying degrees and some in great detail, while a few AIs demonstrated over-reliance on the vendor and were only able to provide a more simplistic response, without being able to provide clear reasons why specific settings had been adopted.

1.2 Where a group-wide policy is in place, AIs must understand and be able to justify, in line with compliance policies and risk appetite, any variations in system settings or configuration adopted locally which impacts performance of the system. This applies to the lists and data which are entered into systems and against which screening is conducted and also the algorithms / rules utilised (referred to as “system filters”). Some variations were observed in the thematic review while a few AIs were unable to adequately demonstrate how any deviation from the group-wide policy would affect the effectiveness and efficiency of its screening system, such as accuracy and number of alerts generated.

1.3 While not included in the review, as additional guidance, Management Information (MI) should provide senior management with adequate information to understand the financial crime risks to which the AI may be exposed. In the context of sanctions risk management, this may include an overview of the sanctions risks to which the AI is exposed, the effectiveness of certain aspects of system performance, such as screening and relevant information regarding volume of alerts, details of false positives, genuine sanctions hits, etc.   

2. New systems, or upgrades to existing systems need to be thoroughly tested and tuned prior to deployment, with sufficient levels of reporting and oversight

2.1 A few AIs were not able to demonstrate that adequate testing had taken place before system deployment. As a good practice, AIs should take steps to satisfy themselves the system is appropriate and operating as expected before relying on automated screening systems. If an AI is upgrading an existing screening system, testing should be conducted prior to deployment to check that all system filters work properly and that the new system is an improvement over the old one. AIs should document that testing and analysis have been duly conducted.

3. Ongoing monitoring, tuning and testing should be conducted on all aspects of sanctions screening systems, lists and processes on a regular and frequent basis

3.1 AIs are expected to have an adequate understanding of their obligations under the sanctions regime in Hong Kong and, as applicable, in other jurisdictions in relation to AI’s international operations. Generally, most of the AIs examined in the thematic review had an adequate understanding of the above obligations.

3.2 Most AIs carried out quality assurance work on the effectiveness of their sanctions systems, although frequency and intensity varied. Many AIs had systems validated by external vendors and where this was the case, there was generally a better understanding of system / filter performance and the various factors underpinning such performance. Most AIs in the review exercise expressed that system effectiveness was one of the more challenging areas to test, since it required dummy data to validate the end result. It should be noted that regardless of how testing is performed, the testing process should be independent and provide the level of validation required.

3.3 With regards to frequency of testing, running a test once a year or every few years will not provide sufficient ongoing comfort that best efforts are being made to meet obligations. Testing must be performed frequently to maintain a system which is both effective and efficient, ensuring that latest sanctions list changes are tested and that system filters are operating within expectations.

As revealed in the thematic review, a few AIs which did not carry out frequent testing and tuning internally were unable to demonstrate an adequate understanding of system filter performance and had not collated the necessary information and data to make correct decisions with regards to system settings.

4. AIs are expected to have a clear and demonstrable understanding of the system filters utilised in their screening technology, and to employ / equip staff with the right skills and knowledge to support the deployment of effective sanctions screening systems

4.1 Many AIs as examined in the review had developed appropriate internal training programmes for staff in key roles. During the post-test interviews, these AIs with training programmes and relevant subject matter expertise demonstrated a more thorough understanding of system filter performance. It was apparent in a few other interviews, however, that staff had not been provided with the right skills to support effective system deployment.

4.2 Most AIs in the review exercise were able to clearly describe specific decisions around the lists their system operated and the filters employed. Explanations for each setting within the system should be properly documented. The review also revealed a few AIs that had limited knowledge of system filter performance or whether certain sanctions lists were in scope of the screening system or not.

4.3 There should also be clarity around ownership and accountability of the risk and which functions, compliance or information technology units, should contribute to managing that risk, for example, by ensuring that sanctions lists are kept up to date.

4.4 Suppression (or good guy/false hit) lists should be subject to particularly robust oversight. The reason for the inclusion of each entry should be documented properly, and these lists should be subject to regular maintenance and reviews. Appropriate approval should also be sought with respect to these regular reviews, as well as prior to the inclusion of any entry into these lists. 

5. AIs are expected to conduct ongoing tuning of system filters to reduce the level of false positives without compromising effectiveness

5.1 AIs should understand their required level of effectiveness based on risk appetite, but should at the same time tune the system for greater efficiency where possible. Most AIs in the review understood the competing relationship between effectiveness and efficiency of the system and could evidence this understanding through actions such as monitoring levels of false positives. In those AIs where there was proactive and ongoing fine tuning to achieve greater efficiency, there was also a more comprehensive understanding of how the system, and the filters employed, operated. In a few AIs we noted high volumes of alerts, and where there were great dependency on vendor support and a general lack of awareness of the need for system optimization in one or two cases.   

Link:

HKMA Notice

Edited with BlogPad Pro

Myanmar/Burma: EU extends and strengthens its arms embargo, and adopts a framework for targeted measures against officials responsible for serious human rights violations

On 26 April, the Council imposed further restrictive measures on Myanmar/Burma, strengthening the EU’s arms embargo and targeting the Myanmar/Burma army and border guard police officials.

The Council extended the existing embargo on arms and equipment that can be used for internal repression for one year. In addition, it prohibited the export of dual-use goods for use by the military and border guard police and imposed restrictions on the export of equipment for monitoring communications that might be used for internal repression. The Council also prohibited the provision of military training to and military cooperation with the Myanmar/Burma army.

The Council also adopted a legal framework for targeted restrictive measures against certain persons from the Myanmar Armed Forces (Tatmadaw) and the border guard police. It will make it possible, should crimes continue to go unpunished, to impose a travel ban and an asset freeze on individuals responsible for:

• serious human rights violations, for example inciting violence, for discrimination and acts of violence against persons belonging to minorities in Rakhine and for obstructing the voluntary and safe return process of displaced persons from Rakhine State to their place of origin;
• for obstructing the conduct of independent investigations into alleged serious human violations or abuses;
• for obstructing the rapid and unimpeded passage of humanitarian assistance for civilians in need.

The decisions adopted today are a direct follow up to the Foreign Affairs Council conclusions of 26 February 2018 on the situation in Myanmar/Burma, which called for concrete options for the strengthening of the current embargo and for proposals for targeted restrictive measures against senior military officers of the Myanmar armed forces (Tatmadaw) responsible for serious and systematic human rights violations.

Taking note of the situation, in particular in Rakhine State, which remains extremely serious, the Council condemned ongoing widespread, systematic grave human rights violationscommitted by Myanmar/Burma military and security forces, including rape and killings, and called upon the Government of Myanmar/Burma and the security forces to ensure that security, the rule of law and accountability prevail in Myanmar/Burma, including in Rakhine, Kachin and Shan States.

The legal acts were adopted by the Council by written procedure. They will be published in the Official Journal of 27 April.

Link:

EU Notice

Edited with BlogPad Pro

Last Thursday, Australian officials adopted the changes to the following Yemen sanctions listing: 

YEi.003 Name: 1: ALI 2: ABDULLAH 3: SALEH 4: na Name (original script) الله عبد علي

صالح Title: na Designation: a) President of Yemen’s General People’s Congress party b) Former 

President of the Republic of Yemen DOB: a) 21 Mar. 1945 b) 21 Mar. 1946 c) 21 Mar. 1942 d) 

21 Mar. 1947 POB: a) Bayt al-Ahmar, Sana’a Governorate, Yemen b) Sana’a, Yemen c) Sana’a, 

Sanhan, Al-Rib’ al-Sharqi Good quality a.k.a.: Ali Abdallah Salih Low quality a.k.a.: na 

Nationality: Yemen Passport no: 00016161 (Yemen) National identification no: 01010744444 

Address: na Listed on: 7 Nov. 2014 (amended on 20 Nov. 2014, 23 April 2018) Other information: 

Gender [Male]. Status: reportedly deceased. INTERPOL-UN Security Council Special Notice 

web link: https://www.interpol.int/en/ notice/search/un/5837306

as adopted by the relevant United Nations Sanctions Committee.

Link:

UN Notice

Edited with BlogPad Pro

Last Thursday, OFAC removed the following 2 counter narcotics sanctions listings for one entity:

And amended the following listing:

Additionally, Treasury issued the following press release about the removed entity:

Links:

OFAC Notice

Treasury Press Release

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