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January 20, 2020: OFSI amends a TAFA, renews 2 Litvinenko-related designations

On Monday, UK regulators updated the following Final Designation under its Terrorist Asset-Freezing etc. Act 2010 (TAFA) program, to denote his demise:


Title: Major General DOB: 11/03/1957. POB: Qom, Iran a.k.a: (1) SALIMANI, Qasem (2) SOLAIMANI, Qasem (3) SOLEIMANY, Qasim (4) SOLEMANI, Qasem (5) SOLEYMANI, Ghasem (6) SOLEYMANI, Qasem (7) SULAIMANI, Qasem (8) SULAYMAN, Qasem (9) SULAYMAN, Qasmi (10) SULEMANI, Qasem Nationality: Iranian (Iranian citizenship) Passport Details: 008827 issued in Iran Position: Commander of Iranian Revolutionary Guard Corps, IRGC – Qods Other Information: (Deceased). Both UK listing and EU listing under Terrorism and Terrorist Financing. EU listing under Syria. Promoted to Major General, retaining his position as Commander of Qods Force. UN listing under Iran (nuc prol). Male. UN Ref IRi.039. Also known as Haj Qasem, Haji Qassem and Sarder Soleimani. Listed on: 17/10/2011 Last Updated: 10/07/2019 20/01/2020 Group ID: 9062.

Additionally, 2 designations made under the Anti-terrorism, Crime and Security Act 2001 (ATCSA) were renewed:

1. KOVTUN, Dmitri Vadimovich

DOB: (1) 25/09/1965. (2) 25/09/1969. POB: Moscow a.k.a: KOVTUN, Dmitry, Vadimovich Passport Details: Reference 62. Passport no. 9632078. issued 17/08/2006. expired 17/08/2011 Address: Apartment no. 150, Golubinskay Street, Moscow, Russia, 117463. Position: General Director of Gobal Project Listed on: 22/01/2016 Last Updated: 22/01/2018 20/01/2020 Group ID: 13311.

2. LUGOVOY, Andrey Konstantinovich

DOB: 19/09/1966. POB: Baku, Azerbaijan a.k.a: LUGOVOI, Andrey, Konstantinovich Passport Details: Reference 51. Passport no. 0608109. issued 18/11/2005. expiring 03/05/2009 Address: Soloviniya Proezcl, 16-1-247, Moscow, Russia, 117593. Position: Member of the Russian Duma (Parliament) Listed on: 22/01/2016 Last Updated: 22/01/2018 20/01/2020 Group ID: 13310.

These two individuals were both implicated in the poisoning death of Alexander Litvinenko.

For those of us less familiar with ATCSA (like Mr. Watchlist), here are some excerpts from the Notice (a section on challenging the freezing order has been removed):

Notice summary

2. The Treasury has made the freezing orders with effect from 18 January 2020

3. This means that Andrey LUGOVOY and Dmitri KOVTUN, persons originally specified for the purposes of the Order dated 22 January 2016 made under the Anti-terrorism, Crime and Security Act 2001 (“the Act”), are now subject to the financial sanctions imposed in the Freezing Order which comes into force on 18 January 2020

What you must do


You must:

i. check whether you maintain any accounts or hold any funds or economic resources for the persons set out in the Annex to this Notice;

ii. freeze such accounts, and other funds or economic resources;

iii. refrain from dealing with the funds or assets or making them available (directly or indirectly) to such persons unless licensed by the Office of Financial Sanctions Implementation (OFSI);

iv. report any findings to OFSI, together with any additional information that would facilitate compliance with the Regulation;

v. provide any information concerning the frozen assets of designated persons that OFSI may request. Information reported to OFSI may be passed on to other regulatory authorities or law enforcement.

5. Where a relevant institution has already reported details of accounts, other funds or economic resources held frozen for designated persons, they are not required to report these details again.

6. Failure to comply with financial sanctions legislation or to seek to circumvent its provisions is a criminal offence.

Other Information

9. Under the Act, HM Treasury may make a freezing order which prohibits persons from making funds available to or for the benefit of a person or persons specified in that order. This order may be made where the Treasury has a reasonable belief that persons specified in the order have taken or are likely to take action which is to the detriment of the UK economy; or a threat to the life or property of one or more nationals or residents of the UK.

10. The Treasury’s Consolidated List of persons subject to financial sanctions in effect in the UK, which is maintained on the website, has been updated to reflect the designations.




Categories: Anti-Terrorism, Crime and Security Act 2001 updates OFSI Updates Russia sanctions Sanctions Lists UK Freezing Orders


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