Earlier today, Australian regulators added the following 2 individuals:

QDi.423 Name: 1: ALI 2: MAYCHOU 3: na 4: na
Name (original script): علي ما يشو
Title: na Designation: na DOB: 25 May 1983 POB: Taza, Morocco Good quality a.k.a.: a) Abderahmane al Maghrebi b) Abderrahmane le MarocainLow quality a.k.a.: Abou Abderahmane Sanhaji Nationality: MoroccoPassport no: Morocco number V06359364 National identification no: Morocco identity card AB704306 Address: Mali Listed on: 14 Aug. 2019Other information: Member of Al Qaida in the Islamic Maghreb (AQIM) (QDe.014), Ansar Eddine (QDe.135), and Jama’a Nusrat ul-Islam wa al-Muslimin (JNIM) (QDe.159). Physical description: height: 185 cm; weight: 80 kg INTERPOL-UN Security Council Special Notice web link: www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals

QDi.424 Name: 1: BAH 2: AG MOUSSA 3: na 4: na
Title: na Designation: na DOB: na POB: na Good quality a.k.a.: a) Ag Mossa b) Ammi Salim Low quality a.k.a.: na Nationality: Mali Passport no: naNational identification no: na Address: na Listed on: 14 Aug. 2019 Other information: Founding member of Ansar Eddine (QDe.135), operational leader of Jama’a Nusrat ul-Islam wa al-Muslimin (JNIM) (QDe.159). INTERPOL-UN Security Council Special Notice web link: www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals

to its Consolidated List after their addition by the United Nations ISIL (Da’esh) and Al-Qaida Sanctions Committee.


UN Notice

Updated sanction message

The State Secretariat for Economic Affairs (SECO) has published an amendment to Annex 2 of the Ordinance of 2 October 2000 on Measures against Persons and Organizations Related to Usama bin Laden, the Al-Qaïda or the Taliban (SR 946.203).

By decision of 14 August 2019, the relevant UN Sanction Committee amended the list of persons, companies and organizations sanctioned in this context. The change is directly applicable in Switzerland.

On 15 August 2019, SECO therefore adapted the Swiss sanctions database SESAM (SECO Sanctions Management), which was decisive for Switzerland, and published the adaptation on its website .

Financial Intermediaries are requested to immediately block the relevant assets and to report such business relationships to SECO in accordance with the provisions of the Regulation. Notification to SECO does not release a financial intermediary from reimbursing reports to the Money Laundering Reporting Office without delay if the requirements are fulfilled, in accordance with Art. 9 of the Money Laundering Law.

On Friday, Swiss authorities added:

SSID: 10-40870 Foreign identifier: QDi.423 Name: Ali Maychou

DOB: 25 May 1983 POB: Taza, Morocco Good quality a.k.a.: a) Abderahmane al Maghrebi b) Abderrahmane le Marocain Low quality a.k.a.: Abou Abderahmane Sanhaji Address: Mali Nationality: Morocco Identification document: a) Passport No. V06359364, Morocco (Morocco number) b) ID card No. AB704306, Morocco (Morocco identity card)

Relation: a) Member of The Organization of Al-Qaida in the Islamic Maghreb (QE.T.14.01., SSID 10-17785) b) Member of Ansar Eddine (QE.A.135.13., SSID 10-24350) c) Member of Jama’a Nusrat ul-Islam wa al-Muslimin (JNIM) (QDe.159, SSID 10-39764) Other information: Physical description: height: 185 cm; weight: 80 kg INTERPOL-UN Security Council Special Notice web link available. Modifications: Listed on 14 Aug 2019

SSID: 10-40887 Foreign identifier: QDi.424 Name: Bah Ag Moussa

Good quality a.k.a.: a) Ag Mossa b) Ammi Salim Nationality: Mali

Relation: a) Founding member of Ansar Eddine (QE.A.135.13., SSID 10-24350) b) Operational leader of Jama’a Nusrat ul-Islam wa al-Muslimin (JNIM) (QDe.159, SSID 10- 39764) Other information: INTERPOL-UN Security Council Special Notice web link available. Modifications: Listed on 14 Aug 2019

and amended:

SSID: 10-17293 Foreign identifier: QE.A.2.01. Name: Al-Itihaad Al-Islamiya / AIAI Relation: a) Leadership included Hassan Dahir Aweys (QI.D.42.01., SSID 10-14871) b) Received funds through the Al-Haramain Islamic Foundation (Somalia) (QE.A.72.02., SSID 10-17262) Other information: Reported to have operated in Somalia and Ethiopia and to have merged with Harakat Al-Shabaab Al-Mujaahidiin (Al-Shabaab), which was accepted as an affiliate of Al-Qaida (QE.A.4.01) by Aiman Muhammed Rabi al-Zawahiri (QI.A.6.01) in Feb 2012, and is also subject to the sanctions measures set out in Security Council resolution 1844 (2008) concerning Somalia and Eritrea (see http://www.un.org/sc/committees/751/index.shtmlhttps://www.un.org/sc/suborg/en/sanctions/751). Leadership included Hassan Abdullah Hersi Al-Turki and Hassan Dahir Aweys (QI.D.42.01.).). AIAI has received funds through the Al-Haramain Islamic Foundation (Somalia) (QE.A.72.02). Review pursuant to Security Council resolution 1822 (2008) was concluded on 21 Jun 20102010. INTERPOL-UN Security Council Special Notice web link available. Modifications: Amended on 19 Apr 2013, 8 Feb 2019, 14 Aug 2019


FINMA Notice

Data files of updates – PDF, XML

OFSI to update consolidated list links

In 2 weeks time, OFSI will update links to the consolidated list, the system it uses to publish the details of individuals and entities subject to financial sanctions.

The consolidated list extracts will have new updated links on the gov.uk website. It is important that any bookmarks to the old links for each format are updated to the new links.

In addition to the existing five formats in which OFSI currently publishes the consolidated list (html, csv, xls, pdf and txt), it will now also be published as an .xml file. The files themselves will be updated as and when there are changes to the consolidated list and you will continue to be able to use the consolidated list as you do now.

There will also be a new search tool to help individuals and organisations identify targets of financial sanctions more easily. This allows users to quickly search the list of asset-freeze targets and the list of targets subject to restrictions on financial markets and services.

Further details will be published in the coming weeks. OFSI will be updating current links to the consolidated list on 30th August 2019. 

You’d think I wouldn’t have to write about how, if you don’t want to run afoul of US laws and regulations, you actually have to read them… but I did. I can’t tell you how many times, when I go overseas, I get complaints about how complex it all is.

Yeah, but… it is what it is.

The article touches on 3 sets of prominent examples: the CAPTA List, Section 311 of the USA PATRIOT Act and the Special Measures imposed by FinCEN, and the recent jostling over a subpoena issued to three Chinese banks (under the threat of penalties under Section 319 of the USA PATRIOT Act).

Read The Long Arm of the Law here… bottom line is that you can’t avoid the landmines if you don’t attempt to find where they are.

The Secretary of State is publicly designating Anselem Nhamo Sanyatwe, former Commander of the Zimbabwe National Army’s Presidential Guard Brigade and current Ambassador Designate of Zimbabwe to Tanzania, under Section 7031(c) of the FY 2019 Department of State, Foreign Operations, and Related Programs Appropriations Act (Div. F, P.L. 116-6), due to his involvement in gross violations of human rights.  Section 7031(c) provides that, in cases where the Secretary of State has credible information that foreign officials have been involved in significant corruption or a gross violation of human rights, those individuals and their immediate family members are ineligible for entry into the United States.  The Department has credible information that Anselem Nhamo Sanyatwe was involved in the violent crackdown against unarmed Zimbabweans during post-election protests on August 1, 2018 that resulted in six civilian deaths.

The law also requires the Secretary of State to publicly or privately designate such officials and immediate family members.  In addition to the designation of Anselem Nhamo Sanyatwe, the Department is also publicly designating his spouse, Chido Machona.

To date, the Government of Zimbabwe has held no member of the security forces accountable for the acts of violence committed against Zimbabweans on August 1, 2018.  Furthermore, there has been no accountability for the excessive use of force by Zimbabwean security forces on civilians in January and February this year, which reportedly resulted in at least 13 deaths, 600 victims of violence, torture or rape, and more than 1,000 arrests.  We again call on Zimbabwean authorities to hold accountable those officials responsible for human rights violations and abuses in Zimbabwe.


State Department Press Release

This one’s pretty cut and dried… a $343,315 fine for accepting the business of collecting the $5,730,680.33 debt from a company on the SDN List, and for actually successfully collecting $4,043,174.25 of it. The company did not voluntarily self-report, but the two violations were considered a non-egregious case. The resulting settlement was reduced from the $590,282 base penalty.

Here is what OFAC considered in its investigation:

The following were considered aggravating factors:

  • ATCI did not undertake any meaningful analysis or otherwise seek confirmation from OFAC that assignment of the SDN’s debt and acceptance of payment from the Soho Mall Trust was permissible under existing authorizations; and
  • ATCI is a subsidiary of a sophisticated global trade credit insurance and collections conglomerate.

The following were considered mitigating factors:

  • ATCI has not received a penalty notice or Finding of Violation from OFAC in the five years preceding the earliest date of the transactions giving rise to the Apparent Violations; and
  • ATCI voluntarily conducted a full internal review of the underlying facts and circumstances, provided documents from its internal review to OFAC in the course of the investigation, and took voluntary remedial action to address the cause of the Apparent Violations. ATCI also agreed to undertake certain compliance commitments to ensure that its OFAC sanctions compliance program remains strong over the next several years.

and the lesson we should learn:

This enforcement action draws particular attention to transactions related to the assignment of an SDN’s debt and highlights the importance of obtaining a specific license before engaging in activity that is not otherwise authorized.

One curious thing is that ATCI didn’t get credit for the fact that the debt collection may have been licensable: the SDN was in liquidation when ATCI took on the assignment. I know that OFAC has mentioned “could have been licensed” in other cases.

Also interesting is OFAC’s focus on some of these smaller cases. It used to be that the focus was on larger and more egregious patterns of behavior. When you really get down to it, this was a single transaction they got whacked for – maybe because they were a sub of a large firm, they got penalized just to make a point?


Enforcement Information

Yesterday, under the authority of the United Nations and European Union Financial Sanctions (Linking) Regulations 2017, UK regulators added the following persons:


DOB: 25/05/1983. POB: Taza, Morocco a.k.a: (1) AL MAGHREBI, Abderahmane (2) LE MAROCAIN, Abderrahmane (3) SANHAJI, Abou, Abderahmane Nationality: Moroccan Passport Details: Morocco passport number: V06359364 National Identification no: Morocco identity card AB704306 Address: Mali. Other Information: Un Ref QDi.423. Member of Al Qaida in the Islamic Maghreb (AQIM) (QDe.014), Ansar Eddine (QDe.135), and Jama’a Nusrat ul-Islam wa al-Muslimin (JNIM) (QDe.159). Physical description: height: 185 cm; weight: 80 kg. Listed on: 15/08/2019 Last Updated: 15/08/2019 Group ID: 13789.


a.k.a: (1) AG MOSSA (2) SALIM, Ammi Nationality: Mali Other Information: UN Ref QDi.424. Founding member of Ansar Eddine (QDe.135), operational leader of Jama’a Nusrat ul-Islam wa al-Muslimin (JNIM) (QDe.159). Listed on: 15/08/2019 Last Updated: 15/08/2019 Group ID: 13790.

to their ISIL (Da’esh) and Al-Qaida counter terrorism sanctions program.


OFSI Notice