North Korea Sanctions & Enforcement Actions Advisory Issued: July 23, 2018

Title: Risks for Businesses with Supply Chain Links to North Korea

The U.S. Department of State, with the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Homeland Security’s (DHS) Customs and Border Protection (CBP) and Immigration and Customs Enforcement (ICE), is issuing this advisory to highlight sanctions evasions tactics used by North Korea that could expose businesses – including manufacturers, buyers, and service providers – to sanctions compliance risks under U.S. and/or United Nations sanctions authorities. This advisory also assists businesses in complying with the requirements under Title III, the Korean Interdiction and Modernization of Sanctions Act of the Countering America’s Adversaries Through Sanctions Act (CAATSA). Businesses should be aware of deceptive practices employed by North Korea in order to implement effective due diligence policies, procedures, and internal controls to ensure compliance with applicable legal requirements across their entire supply chains.

Multiple U.S. and UN sanctions impose restrictions on trade with North Korea and the use of North Korean labor.1 The two primary risks are: (1) inadvertent sourcing of goods, services, or technology from North Korea; and (2) the presence of North Korean citizens or nationals in companies’ supply chains, whose labor generates revenue for the North Korean government. This advisory also provides due diligence references for businesses.

North Korea’s system of forced labor operates both domestically and internationally. In North Korea, most laborers work between 12 and 16 hours per day (and sometimes up to 20 hours per day) with only one or two rest days per month in jobs they are assigned to by the North Korean government. Outside of North Korea, there are two primary groups of North Korean laborers earning income: (1) North Korean overseas laborers whose primary work is organized, managed, and overseen by, and produces revenue for, the North Korean government; and (2) North Koreans who have fled North Korea, including refugees and asylum seekers who live and work outside of North Korea and are earning income to sustain themselves in a personal capacity.

The U.S. government is focusing its disruption efforts on North Korean citizens or nationals whose labor generates revenue for the North Korean government. In most cases, employers pay salaries directly to the North Korean government, which takes between 70 percent and 90  percent of the total earnings. The North Korean government reportedly earns hundreds of millions of U.S. dollars per year from exporting labor. These remittances support the North Korean government’s weapons of mass destruction (WMD) and ballistic missile programs. Use of North Korean citizens or nationals as laborers in supply chains could trigger U.S. sanctions, and the issuance of work authorizations for these North Korean nationals is prohibited under UN Security Council resolution 2397 (2017).

The U.S. government is not seeking to disrupt the efforts of North Korean refugees and asylum seekers, who are living and working outside of North Korea, to earn an income to sustain themselves in a personal capacity. Individuals originally from North Korea, who obtain South Korean citizenship or any other citizenship, are no longer considered North Korean citizens or nationals, for purposes of CAATSA § 321 (b).

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Press Releases

Link:

HKMA Alert

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Press Releases

Link:

HKMA Notice

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On Wednesday, OFAC added the following persons: 

AJAKA, Tony (a.k.a. AJAKA, Antoine); DOB 14 Mar 1968; nationality Lebanon (individual) [NPWMD] (Linked To: KATRANGI, Amir). 

 

BEURKLIAN, Anni (a.k.a. AJAKA, Anni); DOB 17 May 1969; nationality Lebanon; citizen United States (individual) [NPWMD] (Linked To: KATRANGI, Amir). 

 

CHAHINE, Mireille; DOB 01 Mar 1983; POB Beirut, Lebanon; nationality Lebanon; Employee and Accountant at Electronic Katrangi Group (individual) [NPWMD] (Linked To: ELECTRONICS KATRANGI TRADING). 

 

KATRANGI, Amir (a.k.a. ALKANTRANJI, Amir Hachem; a.k.a. KANTRAJI, Amir Hachem; a.k.a. KATRA, Amir; a.k.a. KATRANGI, Amir Hachem; a.k.a. KATRANJI, Amir; a.k.a. KATRANJI, Amir Hachem; a.k.a. KATRANJI, Amir Hashem); DOB 24 Jun 1966; POB Hama, Syria; nationality Syria; Managing Director and Co-founder of Electronic Katrangi Group (individual) [NPWMD] (Linked To: ELECTRONICS KATRANGI TRADING). 

 

KATRANGI, Houssam (a.k.a. EL KATRANGI, Houssam Hachem; a.k.a. EL KATRANJI, Houssam Hachem; a.k.a. KATRANGI, Houssam Hachem; a.k.a. KATRANGI, Hussam; a.k.a. KATRANJI, Houssam Hachem; a.k.a. KATRANKI, Houssam Hashem; a.k.a. QATRANJI, Hussam), Khansa Jnah, Beirut, Lebanon; DOB 27 Nov 1973; POB Ramlet El Baida, Lebanon; nationality Lebanon; Co-founder and Associate of Electronic Katrangi Group (individual) [NPWMD] (Linked To: ELECTRONICS KATRANGI TRADING). 

 

KATRANGI, Maher (a.k.a. EL KATRANGI, Maher Hachem; a.k.a. EL KATRANJI, Maher Hachem; a.k.a. KATRANGI, Maher Hachem; a.k.a. KATRANGI, Maher Mohamad; a.k.a. KATRANJI, Maher Hachem; a.k.a. KATRANJI, Maher Hashem), Khansa Jnah, Beirut, Lebanon; DOB 06 Jul 1967; POB Hama, Syria; nationality Syria; Co-founder and Associate of Electronic Katrangi Group (individual) [NPWMD] (Linked To: ELECTRONICS KATRANGI TRADING). 

 

KATRANGI, Mohamad (a.k.a. ALKTRANJI, Mohammed; a.k.a. KATRANJI, Mohammed); DOB 1928 (individual) [NPWMD] (Linked To: ELECTRONICS KATRANGI TRADING). 

 

ZHOU, Yishan; DOB 08 Dec 1981; POB Guangdong, China; nationality China; Director, EKT Smart Technology (individual) [NPWMD] (Linked To: EKT SMART TECHNOLOGY).  

and entities: 

EKT SMART TECHNOLOGY, 38 Dongtang Jinguang South Road, Xiashan Street, Chaonan District, Guangdong to Shantou, China; Chase Business Centre, 39-41 Chase Side, London N14 5BP, United Kingdom; Company Number 08884792 (United Kingdom) [NPWMD] (Linked To: ELECTRONICS KATRANGI TRADING). 

 

ELECTRONICS KATRANGI TRADING (a.k.a. AL AMIR ELECTRONICS; a.k.a. ALAMIR ELECTRONICS; a.k.a. AL-AMIR ELECTRONICS; a.k.a. AMIRCO ELECTRONICS; a.k.a. E.K.T. (KATRANGI BROS.); a.k.a. EKT (KATRANGI BROS); a.k.a. EKT ELECTRONICS; a.k.a. EKT KATRANGI BROTHERS; a.k.a. ELECTRONIC KATRANGI GROUP; a.k.a. KATRANGI ELECTRONICS; a.k.a. KATRANGI FOR ELECTRONICS INDUSTRIES; a.k.a. KATRANGI TRADING; a.k.a. KATRANJI LABS; a.k.a. LUMIERE ELYSEES (Latin: LUMIÈRE ELYSÉES); a.k.a. NKTRONICS; a.k.a. SMART GREEN POWER; a.k.a. SMART PEGASUS; a.k.a. “E.K.T.”; a.k.a. “EKT”; a.k.a. “ELECTRONIC SYSTEM GROUP”; a.k.a. “ESG”), 1st Floor, Hujij Building, Korniche Street, P.O. Box 817 No. 3, Beirut, Lebanon; P.O. Box 8173, Beirut, Lebanon; #1 fl., Grand Hills Bldg., Said Khansa St., Jnah (BHV), Beirut, Lebanon; 11/A, Abbasieh Building, Hijaz Street, Damascus, Syria; Lahlah Building, Industrial Zone, Hama, Syria; Awqaf Building, Naser Street, P.O. Box 34425, Damascus, Syria; #1 floor, 02/A, Fares Building, Rami Street, Margeh, Damascus, Syria; 46 El-Falaki Street, Facing Cook Door, BabLouk Area, Cairo, Egypt; Website http://www.ekt2.com; alt. Website http://www.katranji.com; alt. Website http://sgp-france.com; alt. Website http://lumiere-elysees.fr; Identification Number 808 195 689 00019 (France); Chamber of Commerce Number 2014 B 24978 (France) [NPWMD] (Linked To: SCIENTIFIC STUDIES AND RESEARCH CENTER). 

 

GOLDEN STAR CO (a.k.a. GOLDEN STAR INTERNATIONAL FREIGHT LIMITED; a.k.a. GOLDEN STAR TRADING & INTERNATIONAL FREIGHT; a.k.a. GOLDEN STAR TRADING AND INTERNATIONAL FREIGHT; a.k.a. GOLDEN STAR TRADING INTERNATIONAL FREIGHT; a.k.a. KASSOUMA FZC; a.k.a. SHAREKAT GOLDEN STAR; a.k.a. SMART LOGISTICS F.S.S.A.L; a.k.a. SMART LOGISTICS OFFSHORE; a.k.a. SMART LOGISTICS TRADING & INTERNATIONAL FREIGHT; a.k.a. SMART LOGISTICS TRADING AND INTERNATIONAL FREIGHT), Al Awqaf building, 5th floor, Victoria Bridge, Damascus, Syria; 2 Floor, Inana Bldg, Damascus Free Zone, Damascus, Syria; Room 707, Fulijinxi Business Center, No. 05, Fuchang Road, Haizhu District, Guangzhou, China; Al Alshiah, Mar Mekheal Church, Amicho Building, 3rd Floor, Beirut, Lebanon; Office 112, First Floor, Al Manara Building, Port Street, Beirut, Lebanon; Website http://www.goldenstar-co.com [NPWMD] (Linked To: ELECTRONICS KATRANGI TRADING). 

 

POLO TRADING, Fakhani Building, Korniche Mazraa Street, Beirut, Lebanon; Grand Hills/GF Al Khansa St., Beirut, Lebanon; Website polo-trading.com [NPWMD] (Linked To: KATRANGI, Amir). 

 

TOP TECHNOLOGIES SARL, Ground Floor, Dedeyan center, Dora highway, Metn, Bauchrieh, Lebanon [NPWMD] (Linked To: AJAKA, Tony).

to its non-proliferation of weapons of mass destruction (NPWMD) sanctions program.

Additionally, they removed the following listings from the Ukraine/Russia-related sanctions program:

EESTI KREDIIDIPANK AS (a.k.a. AS EESTI KREDIIDIPANK; a.k.a. ESTONIAN CREDIT BANK; a.k.a. JOINT-STOCK COMPANY EESTI KREDIDIPANK), Narve Road 4, Tallinn 15014, Estonia; SWIFT/BIC EKRD EE 22; Website http://www.krediidipank.ee; Executive Order 13662 Directive Determination – Subject to Directive 1; All offices worldwide; for more information on directives, please visit the following link: https://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] (Linked To: BANK OF MOSCOW). 

 

AS EESTI KREDIIDIPANK (a.k.a. EESTI KREDIIDIPANK AS; a.k.a. ESTONIAN CREDIT BANK; a.k.a. JOINT-STOCK COMPANY EESTI KREDIDIPANK), Narve Road 4, Tallinn 15014, Estonia; SWIFT/BIC EKRD EE 22; Website http://www.krediidipank.ee; Executive Order 13662 Directive Determination – Subject to Directive 1; All offices worldwide; for more information on directives, please visit the following link: https://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] (Linked To: BANK OF MOSCOW). 

 

ESTONIAN CREDIT BANK (a.k.a. AS EESTI KREDIIDIPANK; a.k.a. EESTI KREDIIDIPANK AS; a.k.a. JOINT-STOCK COMPANY EESTI KREDIDIPANK), Narve Road 4, Tallinn 15014, Estonia; SWIFT/BIC EKRD EE 22; Website http://www.krediidipank.ee; Executive Order 13662 Directive Determination – Subject to Directive 1; All offices worldwide; for more information on directives, please visit the following link: https://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] (Linked To: BANK OF MOSCOW). 

 

JOINT-STOCK COMPANY EESTI KREDIDIPANK (a.k.a. AS EESTI KREDIIDIPANK; a.k.a. EESTI KREDIIDIPANK AS; a.k.a. ESTONIAN CREDIT BANK), Narve Road 4, Tallinn 15014, Estonia; SWIFT/BIC EKRD EE 22; Website http://www.krediidipank.ee; Executive Order 13662 Directive Determination – Subject to Directive 1; All offices worldwide; for more information on directives, please visit the following link: https://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] (Linked To: BANK OF MOSCOW).

Link:

OFAC Notice

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PRESS

Links:

EU Press Release

Draft regulation

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On Thursday, Australian regulators, in addition to fixing some typos and other errors in their Consolidated List, removed the following four entities from the Iraq sanctions program: 

IQe.066 Name: IRAQI TOBACCO STATE ESTABLISHMENT

A.k.a.: IraqI TOBACCO STATE ENTERPRISE F.k.a.: na Address: 

a) Karrada Al Sharkiya, Nadhimiya, P.O. Box 10026, Baghdad, Iraq b) 

P.O. Box 10026, Jumhuriya Street, Khallani Square, Baghdad, Iraq 

Listed on: 26 Apr. 2004 Other information:

IQe.079 Name: MOSUL SUGAR STATE COMPANY

A.k.a.: MOSUL SUGAR STATE ENTERPRISE F.k.a.: na Address: 

P.O. Box 42, Gizlany Street, Mosul, Iraq Listed on: 26 Apr. 2004 

Other information:

IQe.124 Name: STATE ENTERPRISE FOR DAIRY PRODUCTS

A.k.a.: na F.k.a.: na Address: P.O. Box 11183, Baghdad, Iraq Listed 

on: 26 Apr. 2004 Other information:

IQe.145 Name: STATE ENTERPRISE FOR VEGETABLE OILS

A.k.a.: na F.k.a.: na Address: P.O. Box 2379, Muaskar Al Rashid 

Road, Baghdad, Iraq Listed on: 26 Apr. 2004 Other information:

after their removal by the United Nations Sanctions Committee.

Link:

UN Notice

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Mr. Watchlist had written OFAC with questions about securities issued by an SDN, but not covered under the Ukraine/Russia-related or Venezuela government securities sanctions. And, a mere 2 or 3 hours later (bravo!), I got back the following response (reformatted for readability):

• First, for a US person to directly buy or sell in securities of an SDN that would be prohibited, because it would be conveying a benefit on the SDN in assisting with contributing to making a market for the security of the SDN. 
• Second, where a US person purchases a mutual fund with holdings in multiple investments, one of which includes a security of an SDN, this second situation would place the US investor in a position where it is assumed they did not effectuate the trade or make the decision to invest in the security in question. 
  • Then the issue would first be for the mutual fund company whether it is a US person. If so, then the purchase of the securities would likely be considered prohibited. 
  • For the US investor who bought the mutual fund shares without any role in the purchase of the securities of the SDN by the mutual fund company, the US individual investor perspective in this would be further removed from the activity in question. 
  • There would be several factors included in the review of this US individual investor activity, including the amount of size of the SDN security in comparison to the overall mutual fund portfolio, frequency of the trading activity including duration and length, sanctions program involved, reason to know of this investment, etc. 
• Third, where an SDN security has already been sold and was not blocked, then with the security out of the US person’s holdings, the US person may provide correspondence to OFAC indicating what happened with any related supporting documents. They are note required to do so, but it is appreciated and considered favorably.

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Each quarter, a report of the operation of the UK’s counter terrorism asset freezing program under the Terrorist Asset Freezing Act 2010 (TAFA 2010) is published. However, the only part that is publicly issued is the Ministerial statement and some statistics. The report for January through March of 2018 was published on July 11th:

Annex 1

 Written Ministerial Statement

    ____________________________________________________________________

Operation of the UK’s Counter-Terrorist Asset Freezing Regime: 1 January 2018 to 31 March 2018

The Economic Secretary to the Treasury (John Glen): Under the Terrorist Asset-Freezing etc. Act 2010 (TAFA 2010), the Treasury is required to prepare a quarterly report regarding its exercise of the powers conferred on it by Part 1 of TAFA 2010. This written statement satisfies that requirement for the period 1 January 2018 to 31 March 2018.

This report also covers the UK’s implementation of the UN’s ISIL (Da’esh) and Al-Qaida asset freezing regime (ISIL-AQ), and the operation of the EU’s asset freezing regime under EU Regulation (EC) 2580/2001 concerning external terrorist threats to the EU. (also referred to as the CP 931 regime).

Under the ISIL-AQ asset freezing regime, the UN has responsibility for designations and the Treasury, through the Office of Financial Sanctions Implementation (OFSI), has responsibility for licensing and compliance with the regime in the UK under the ISIL (Da’esh) and Al-Qaida (Asset-Freezing) Regulations 2011.

Under EU Regulation 2580/2001, the EU has responsibility for designations and OFSI has responsibility for licensing and compliance with the regime in the UK under Part 1 of TAFA 2010.

A new EU asset freezing regime under EU Regulation (2016/1686) was implemented on 22 September 2016. This permits the EU to make autonomous Al-Qaida and ISIL (Da’esh) listings. The first designation under the regime was made during this quarter, and is recorded in the fifth column of the table below.

The following tables set out the key asset-freezing activity in the UK during the quarter.

The recently passed Sanctions and Anti-Money Laundering Act will help ensure that UK counterterrorist sanctions powers remain a useful tool for law enforcement and

intelligence agencies to consider utilising, while also meeting the UK’s international

obligations.

Under the Act, a designation could be made where there are reasonable grounds to suspect that the person or group is or has been involved in a defined terrorist activity and that designation is appropriate. This approach is in line with the UK’s current approach under UN and EU sanctions and would be balanced by procedural protections such as the ability of designated persons to challenge the Government in court.

Unfortunately, the tables on pages 2 and 3 don’t cut and paste cleanly, so… the link is below.

Link:

Annex 1 of Quarterly Report to Parliament

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PRESS

Link:

EU Notice

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On July 11, Her Majesty’s Treasury (HMT) issued an Advisory Notice about the AML/CTF controls necessary for higher-risk jurisdictions, which also includes copies of FATF’s latest public statements:

Requirement to apply Enhanced Due Diligence for higher risk jurisdictions

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017) require the UK regulated sector to apply enhanced customer due diligence to high-risk countries.

• MLR 2017 Regulation 33 (1) (b) states that regulated businesses (“relevant persons”) must apply enhanced customer due diligence measures and enhanced ongoing monitoring in any business relationship or transaction with a person established in a high-risk third country. For these purposes, Regulation 33 (3) states that a high-risk third country is one identified by the European Commission in delegated acts adopted under Article 9.2 of the Fourth Money Laundering Directive. These delegated acts are set out in Delegated Regulation 2016/1675.

• MLR 2017 Regulation (33) (6) (c) requires that relevant persons must take into account “geographical risk factors” when assessing risk and the extent of measures which should be taken to manage and mitigate that risk. These risk factors are stated as including whether a country is identified by a credible source, including reports published by the Financial Action Task Force (FATF), as not implementing requirements to counter money laundering and terrorist financing that are consistent with FATF recommendations.

As the international anti-money laundering and counter-terrorist financing (AML/CTF) standard-setter, FATF regularly publishes statements that identify high-risk countries based on assessments of their AML/CTF regimes. In line with Regulation (33) (6) (c) HM Treasury would like to draw the regulated sectors attention to the latest publication by FATF on high risk jurisdictions.

Link:

HMT Advisory Notice

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On Friday, Her Majesty’s Treasury (HMT) amended the following Syrian sanctions entity listing: 

COMMERCIAL BANK OF SYRIA

Address: (1) Aleppo Branch, PO Box 2, Kastel Hajjarin St, Aleppo, Syria. (2) Damascus Branch, PO Box 933, Yousef Azmeh Square, Damascus, Syria. (3) Damascus Branch, PO Box 2231, Moawiya St, Damascus, Syria. Other Information: State-owned bank providing financial support to the regime. SWIFT/BIC CMSY SY DA CMSYSDA – all offices worldwide (NPWMD). Website http://cbs-bank.sy/En-index.php. Tel +963 11 2218890. Fax +963 11 2216975. General management dir.cbs@mail.sy. Listed on: 14/10/2011 Last Updated: 14/10/2011 27/07/2018 Group ID: 12203.

in line with a Corrigenda issued by the EU.

Links:

HMT Notice

EU Corrigenda

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Usually, it’s the press release that comes later…

Today, OFAC designated the following 3 persons: 

AL-DAKHIL, Abdul Rehman (a.k.a. AHMAD, Dilshad; a.k.a. AL-DAKHIL, ‘Abd al-Rahman; a.k.a. ALI, Amanat; a.k.a. ALI, Amanatullah; a.k.a. ALI, Amantullah; a.k.a. DILSHAD, Danish; a.k.a. IQBAL, Imanat Ullah), Pakistan; DOB 01 Sep 1964; alt. DOB 01 Mar 1965 to 31 Mar 1965; POB Faisalabad, Pakistan; nationality Pakistan; Gender Male (individual) [SDGT]. 

 

HASSAN, Hameed ul (a.k.a. HASAN, Hameed ul; a.k.a. HASSAN, Hameedul), House number 4, Lane 4, Village flag 2, Dhalwan, Pasrur Tehsil, Sialkot District, Punjab Province, Pakistan; DOB 02 Jan 1980; alt. DOB 02 Nov 1980; POB Sialkot, Pakistan; nationality Pakistan; Gender Male (individual) [SDGT]. 

 

JABBAR, Abdul (a.k.a. JABAR, Abdul), 124 Yasir Ghaffar Town, Okara, Punjab, Pakistan; DOB 03 Feb 1977; nationality Pakistan; Gender Male (individual) [SDGT].

under its counter terrorism sanctions program.

And Treasury beat OFAC to the punch with the press release:

So, who’s the third guy? Maybe State will issue its own press release for him…

Links:

Treasury Press Release 

OFAC Notice

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Part of yesterday’s OFAC counter terrorism designations…

Link:

State Department Press Release

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Yesterday, OFAC replaced Ukraine/Russia-related sanctions General License 13B with 13C, extending the limited timeline for the approved transactions, all related to companies in which Russian oligarch Oleg Deripaska has or had a significant ownership stake, including EN+ Group, GAZ Group and United Company Rusal. The full wording of General License 13C:

DEPARTMENT OF THE TREASURY WASHINGTON, D.C. 20220

OFFICE OF FOREIGN ASSETS CONTROL

Ukraine Related Sanctions Regulations 31 C.F.R. Part 589

GENERAL LICENSE NO. 13C

Authorizing Certain Transactions Necessary to Divest or Transfer

Debt, Equity, or Other Holdings in Certain Blocked Persons

(a) Except as provided in paragraph (d) ofthis general license, all transactions and activities otherwise prohibited by the Ukraine Related Sanctions Regulations, 31 C.F.R. part 589, that are ordinarily incident and necessary (1) to divest or transfer debt, equity, or other holdings in the following blocked persons to a non-U.S. person, or (2) to facilitate the transfer of debt, equity, or other holdings in the following blocked persons by a non-U.S. person to another non-U.S. person, are authorized through 12:01 a.m. eastern daylight time, October 23, 2018:

• Irkutskenergo
• GAZ Auto Plant
• Rusal Capital Designated Activity Company

(c) The transactions and activities authorized in paragraphs (a) and (b) include facilitating, clearing, settling transactions to divest to a non-U.S. person debt, equity, or other holdings EN+ Group PLC, GAZ or Company RUSAL or Other Issuer paragraph including on behalf of U.S. persons.

(d) This general license does not authorize:

(1) The unblocking of any property blocked pursuant to any other part of 31 C.F.R. chapter V;

(2) U.S. persons to sell debt, equity, or other holdings to; to purchase or invest in debt, equity, or other holdings in; or to facilitate such transactions with, directly or indirectly, any person whose property and interests in property are blocked pursuant to 31 C.F.R. part 589, including EN+ Group PLC, GAZ Group, or United Company RUSAL PLC, other than purchases of or investments in debt, equity, or other holdings in those persons, or Other Issuer Holdings as described in paragraph (b) (including settlement of purchases or sales that were pending on April 6, 2018), that are ordinarily incident and necessary to the divestment or transfer of debt, equity, or other holdings in EN+ Group PLC, GAZ Group, or United Company RUSAL PLC, or Other Issuer Holdings as described in paragraph (b);

(3) Any transactions or dealings involving the property or interests in property of any person whose property and interests in property are blocked pursuant to 31 C.F.R. part 589 other than EN+ Group PLC, GAZ Group, or United Company RUSAL PLC, or any entity in which those persons have a 50 percent or greater interest consistent with the authorization in paragraph (b) ofthis general license; or

(4) Any transactions or dealings otherwise prohibited by any other part of 31 C.F.R. chapter V.

(e) U.S. persons participating in transactions authorized by this general license are required, within 10 business days after the expiration date of this general license, to file a comprehensive, detailed report of each transaction, including the names and addresses of parties involved, the type and scope of activities conducted, and the dates on which the activities occurred, with the Office of Foreign Assets Control, Office of Compliance and Enforcement, U.S. Department of the Treasury, 1500 Pennsylvania Avenue N.W., Freedman’s Bank Building, Washington, DC 20220, or via email to OFACReport@treasury.gov.

(f) Effective July 31, 201 8, General License No. 13B, dated May 31, 2018, is replaced and superseded in its entirety by this General License No. 13C.

Links:

OFAC Notice

General License 13C

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Yesterday, Her Majesty’s Treasury (HMT) implemented Commission Implementing Regulation (EU) No 2018/1066 by removing the following 4 entities: 

IRAQI TOBACCO STATE ESTABLISHMENT

a.k.a: Iraqi Tobacco State Enterprise Address: (1) Karrada Al Sharkiya, Nadhimiya, PO Box 10026, Baghdad, Iraq. (2) PO Box 10026, Jumhuriya Street, Khallani Square, Baghdad, Iraq. Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI. Listed on: 05/05/2004 Last Updated: 21/02/2013 31/07/2018 Group ID: 8122.

MOSUL SUGAR STATE COMPANY

a.k.a: Mosul Sugar State Enterprise Address: PO Box 42, Gizlany Street, Mosul, Iraq. Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 31/07/2018 Group ID: 8135.

STATE ENTERPRISE FOR DAIRY PRODUCTS

Address: PO Box 11183, Baghdad, Iraq. Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 31/07/2018 Group ID: 8177.

STATE ENTERPRISE FOR VEGETABLE OILS

Address: PO Box 2379, Muaskar Al Rashid Road, Baghdad, Iraq. Other Information: Funds or financial assets or economic resources received on or after 23 May 2003 are not to be regarded as frozen nor required to be transferred to the successor arrangements to the DFI Listed on: 05/05/2004 Last Updated: 21/02/2013 31/07/2018 Group ID: 8197.

from its Iraq sanctions program.

Links:

HMT Notice

Commission Implementing Regulation (EU) No 2018/1066

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Yesterday, Her Majesty’s Treasury (HMT) implemented Council Implementing Regulation (EU) No 2018/1074 by amending the following 8 individual North Korean sanctions program designations:

1. HYON Chol-Hae

DOB: –/–/1934. POB: Manchuria, China a.k.a: HYON, Chol, Hae Position: Deputy Director of the General Political Department of the Korean People’s Armed Forces (military adviser to Kim Jong Il) Korean People’s Army Marshal since April 2016. Other Information: Annex XV EU Listing not UN. Korean People’s Army Marshal since April 2016. Former Deputy Director of the General Political Department of the Korean People’s Army (military adviser to late Kim Jong Il) Listed on: 30/12/2009 Last Updated: 15/09/2017 31/07/2018 Group ID: 11030.

2. PAK Jae-gyong

DOB: –/–/1933. a.k.a: (1) CHAE-KYONG (2) PAK, Jae, Gyong Passport Details: 554410661 Position: Deputy Director of the General Political Department of the People’s Armed Forces and Deputy Director of the Logistics Bureau of the People’s Armed Forces (military adviser to Kim Jong Il) Other Information: Annex XV. EU listing. Not UN. Former Deputy Director of the General Political Department of the People’s Armed Forces and former Deputy Director of the Logistics Bureau of the People’s Armed Forces (military adviser to late Kim Jong Il) Listed on: 30/12/2009 Last Updated: 15/09/2017 31/07/2018 Group ID: 11036.

3. KIM Jong-gak

Title: Vice Marshal DOB: 20/07/1941. POB: Pyongyang, DPRK a.k.a: KIM, Jong, Gak Position: Vice Marshal in the army of the DPRK Korean People’s Army, rector of the Military University of Kim Il-Sung. Other Information: Annex XV EU Listing not UN. Former Director of the General Political Department of the Korean People’s Army. 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: 20/05/2016 Last Updated: 15/09/2017 31/07/2018 Group ID: 13364.

4. KIM Won-hong

Title: General DOB: 07/01/1945. POB: Pyongyang, DPRK a.k.a: KIM, Won, Hong Passport Details: No: 745310010 Position: General Director of the State Security Department, Minister of State Security First Deputy Director of the General Political Department of the Korean People’s Army. Other Information: Annex XV. EU Listing, Not UN. Former Director of the State Security Department, former Minister of State Security. 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: 20/05/2016 Last Updated: 15/09/2017 31/07/2018 Group ID: 13366.

5. SON Chol-ju

Title: Colonel General a.k.a: SON, Chol, Ju Position: Colonel General of the Korean People’s Armed Forces, Deputy Director responsible for organisation of the Korean People’s Army. & Political Director of the Air & Anti-air Forces. Other Information: Annex XV EU Listing, Not UN. Former Political Director of the Air & Anti-air Forces. Responsible for supporting or promoting the DPRK’s nuclear- related, ballistic-missile-related or other weapons of mass destruction-related programmes. Listed on: 20/05/2016 Last Updated: 15/09/2017 31/07/2018 Group ID: 13368.

6. DJANG Tcheul Hy

DOB: 11/05/1950. POB: Kangwon a.k.a. (1) JANG, Tcheul-hy (2) JANG, Cheul-hy (3) JANG, Chol-hy (4) DJANG, Cheul-hy (5) DJANG, Chol-hy (6) DJANG, Tchoul-hy (7) KIM, Tcheul-hy 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 31/07/2018 Group ID: 13663.

7. 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 (6) KIM, Su-gwang (7) KIM, Son-gwang 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 31/07/2018 Group ID: 13664.

8. JON Chol Young

DOB: 30/04/1975. a.k.a. JON, Chol, Yong Passport Details: Passport Number. 563410192 Position: Diplomat DPRK Embassy Angola Other Information: Annex XVI EU Listing not UN. Representative in Angola of Green Pine Associated Corporation and DPRK diplomat accredited to Angola. Listed on: 22/01/2018 Last Updated: 23/01/2018 31/07/2018 Group ID: 13589.

Links:

HMT Notice

Council Implementing Regulation (EU) No 2018/1074

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Yesterday, Her Majesty’s Treasury (HMT) implemented Council Implementing Regulation (EU) No 2018/1072 by adding the following 6 entities: 

1. AO INSTITUTE GIPROSTROYMOST – SAINT-PETERSBURG

Address: 7 Yablochkova Street, St Petersburg, 197198, Russia. Other Information: AO Institute Giprostroymost – Saint-Petersburg participaed in the construction of the Kerch Bridge through its design of the Bridge. website: http//gpsm.ru and email: office@gpsm.ru. Listed on: 31/07/2018 Last Updated: 31/07/2018 Group ID: 13700.

2. CJSC VAD AKTSIONERNOE OBSHCHESTVO VAD

Address: (1) 122 Grazhdanskiy Prospect, Suite 5, Liter A, St Petersburg, 195267 Russia (2) 133 Chernyshevskogo Street, Vologda, Vologodskaya Oblast, 160019 Russia. Other Information: CJSC VAD is the main contractor for the construction of the Tavrida Highway in Crimea, the road over the Kerch Bridge and the access roads to it. Registration ID: 1037804006811 (Russia). Tax ID No: 7802059185 Website: http://www.zaovad.com. Email: office@zaovad.com Listed on: 31/07/2018 Last Updated: 31/07/2018 Group ID: 13705.

3. JSC ZALIV SHIPYARD

Address: 4 Tankistov Street, 298310 Kerch, Crimea. Other Information: JSC Zaliv Shipyard actively participated in the construction of new railway to the Kerch Bridge, connecting Russia to the illegally annexed Crimean peninsula. Website:http://zalivkerch.com Listed on: 31/07/2018 Last Updated: 31/07/2018 Group ID: 13702.

4. PJSC MOSTOTREST

Address: 6 Barklaya Street, Bld. 5 Moscow, 121087 Russia. Other Information: PJSC Mostotrest actively participated in the construction of the Kerch Bridge through its state contract for the maintenance of the bridge, connecting Russia to the illegally annexed Crimean peninsula. it is owned by an individual (Arkady Rotenberg) that is already designated for his actions undermining Ukrainian sovereignty. Listed on: 31/07/2018 Last Updated: 31/07/2018 Group ID: 13701.

5. STROYGAZMONTAZH CORPORATION (SGM GROUP) OOO

Address: Prospect Vernadskogo 53, Moscow, 119415 Russia. Other Information: Stroygazmontazh Corporation (SGM Group) actively participated in the construction of the Kerch Bridge through its state contract for the consruction of the bridge connecting Russia to the illegally annexed Crimea peninsular. It is owned by an individual (Arkady Rotenberg) that is already designated for his actions undermining Ukraine Sovereignty. Website: http://www.ooosgm.com Listed on: 31/07/2018 Last Updated: 31/07/2018 Group ID: 13703.

6. STROYGAZMONTAZH MOST OOO

Address: Barklaya street 6, buildng 7 Moscow, 121087 Russia. Other Information: Stroygazmontazh Most OOO is a subsidiary of lead contractor Stroygazmontazh that manages the construction project of the bridge over the Kerch Strait. It is owned by an individual (Arkady Rotenberg) that is already designated for his actions undermining Ukrainian Sovereignty. Registration ID: 1157746088170. Tax ID No: 7730018980. Website: http://kerch-most.ru/tag/sgam- most. Email: kerch-most@yandex.ru Listed on: 31/07/2018 Last Updated: 31/07/2018 Group ID: 13704.

to their Ukraine (Sovereignty and Territorial Integrity) sanctions program.

Links:

HMT Notice

Council Implementing Regulation (EU) No 2018/1072

Edited with BlogPad Pro

Seems like it will be a way to get someone’s attention without having to make a new sanctions program…

OFAC, on Wednesday, added the following persons to the Global Magnitsky human rights violations sanctions program:

GUL, Abdulhamit; DOB 12 Mar 1977; POB Nizip, Gaziantep, Turkey; nationality Turkey; Gender Male (individual) [GLOMAG]. 

 

SOYLU, Suleyman; DOB 21 Nov 1969; POB Istanbul, Turkey; nationality Turkey; Gender Male (individual) [GLOMAG].

And the Treasury issued the following press release:

 

August 1, 2018

Washington – The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action today targeting Turkey’s Minister of Justice Abdulhamit Gul and Minister of Interior Suleyman Soylu, both of whom played leading roles in the organizations responsible for the arrest and detention of Pastor Andrew Brunson.  These officials serve as leaders of Turkish government organizations responsible for implementing Turkey’s serious human rights abuses, and are being targeted pursuant to Executive Order (E.O.) 13818, “Blocking the Property of Persons Involved in Serious Human Rights Abuse or Corruption,” which builds upon Treasury’s Global Magnitsky Act authorities. 

“Pastor Brunson’s unjust detention and continued prosecution by Turkish officials is simply unacceptable,” said Treasury Secretary Steven Mnuchin.  “President Trump has made it abundantly clear that the United States expects Turkey to release him immediately.”

Pastor Andrew Brunson has reportedly been a victim of unfair and unjust detention by the Government of Turkey.  He was arrested in Izmir, Turkey in October 2016, and with an absence of evidence to support the charges, he was accused of aiding armed terrorist organizations and obtaining confidential government information for political and military espionage.  

As the head of Turkey’s Ministry of Justice, Abdulhamit Gul is being designated pursuant to E.O. 13818 for being the leader of an entity that has engaged in, or whose members have engaged in, serious human rights abuse. 

As head of Turkey’s Ministry of Interior, Suleyman Soylu is being designated pursuant to E.O. 13818 for being the leader of an entity that has engaged in, or whose members have engaged in, serious human rights abuse.

As a result of these actions, any property, or interest in property, of both Turkey’s Minister of Justice Abdulhamit Gul and Turkey’s Minister of Interior Suleyman Soylu within U.S. jurisdiction is blocked, and U.S. persons are generally prohibited from engaging in transactions with them.

Links:

OFAC Notice

Treasury Press Release

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Earlier today, Her Majesty’s Treasury (HMT) implemented Council Implementing Regulation (EU) No 2018/1073 by removing the following person: from its Libya sanctions program. 

ASHKAL, Omar

POB: Sirte, Libya Position: Head, Revolutionary Committees Movement Other Information: EU listing. Not UN. Revolutionary Committees involved in violence against demonstrators. Believed to have been assassinated in Egypt in August 2014. Closely associated with the former regime of Muammar Qadhafi. Listed on: 03/03/2011 Last Updated: 04/08/2015 01/08/2018 Group ID: 11654.

Links:

HMT Notice

Council Implementing Regulation (EU) No 2018/1073

Edited with BlogPad Pro

Today, OFAC designated the following person: 

RI, Jong Won (a.k.a. RI, Cho’ng-Wo’n; a.k.a. RI, Jung Won), Moscow, Russia; DOB 22 Apr 1971; Passport PS654320421 expires 11 Mar 2019 (individual) [DPRK2].

and entities: 

under the North Korean sanctions program And the following entity:  

And the Treasury Department issued the following press release:

Links:

OFAC Notice

Treasury Press Release

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