Regulatory Filing

The numbers still aren’t enormous – 70,000 GBP total has been frozen under the ISIL/Al-Qaida regime, 18,000 under EU Reg 2580/2001 and 9,000 under TAFA. There were 45 total accounts frozen as of the end of the quarter, and only 2 new designations (both ISIL/AL-Qaida) and 4 delistings (also all ISIL/Al-Qaida) this quarter. There was one TAFA renewal.

Link:

April-June 2019 TAFA Report

Eighth Biennial Report for Licensing Activities Undertaken Pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA)

OFAC has released a Biennial Report of Licensing Activities pursuant to Section 906(c) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA), covering activities undertaken by the Treasury Department’s Office of Foreign Assets Control (OFAC) under Section 906(a)(1) of the TSRA from October 2014 through September 2016.  Under the procedures established in its TSRA-related regulations, OFAC processes license applications requesting authorization to export agricultural commodities, medicine, and medical devices to Iran and Sudan under the specific licensing regime set forth in Section 906 of the TSRA.

Links:

OFAC Notice

TSRA Biennial Report

This is OFAC’s 27th “Annual Report to the Congress on Assets in the United States Relating to Terrorist Countries and Organizations Engaged in International Terrorism” – a mouthful, I know.

Some highlights:

  • $46.181 million in blocked terrorist organization assets, up from $43.606 million in 2017
  • Biggest increases in this group – Hizballah blocked assets increased from $9.814 million to $11.601 million, Hamas went from $1.143 million to $1.364 million, the IRGC-Quds Force increased from $14.491 million to $14.989 million, ISIL went from $251,613 to $657,689, Lashkar-e Tayyiba increased from $218,639 to $397,774, and the Taliban increased from $10,728 to $206,805.
  • State Sponsors of Terrorism have $216.83 million in blocked funds, up from $201.53 million in 2017
  • Of that increase, the overwhelming bulk is due to North Korea (almost $11 million), with Iran ($2.9 million) and Syria ($1.4 million) making up the rest
  • State Sponsors of terrorism own a bit of real estate: Syria owns 4 properties, Iran 11, and Bank Melli indirectly has an ownership interest in a NY building

Link:

Calendar Year 2018 Terrorist Assets Report

The UK publishes a quarterly report about its counter-terrorism sanctions program – and the one for Q4 of 2018 (calendar) is out. Here are the highlights:

  • At the end of the quarter, 9,000 GBP was frozen under TAFA, 18,000 under EU Reg 2580/2001, and 70,000 under the ISIL/Al-Qaida regime (EU Reg 881/2002). These represent 6 TAFA accounts or payments, 3 for EC 2580/2001 and 36 for ISIL-AQ. One item was frozen during the quarter under ISIL-AQ.
  • There were 3 new ISIL-AQ designations during the quarter and one new one under EU Reg 2016/1686 .
  • There were 5 TAFA renewals during the quarter
  • Under the ISIL-AQ regime, 8 licenses were issued during the quarter. And there are still 4 active General Licenses.

Link:

TAFA October-December 2018 Report

The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) Office of Compliance and Enforcement (“OCE”) is issuing OCE’s Data Delivery Standards Guidance

The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) Office of Compliance and Enforcement (“OCE”) is issuing OCE’s Data Delivery Standards Guidance: Preferred Practices for Productions to OFAC (“OCE’s Data Delivery Standards”). OCE’s Data Delivery Standards provides guidance regarding submissions and the technical standards for the preferred format in which to submit electronic document productions to OCE, including administrative subpoena responses, self-disclosures, and other documents or reports. OCE has also updated the Data Delivery Standards to include sections addressing preferred practices for organizing document productions, file size and delivery instructions for electronic submissions, instructions for submitting specific types of files, and an addendum with additional technical document production specifications. This document supersedes and replaces in its entirety, OFAC Enforcement’s 2013 Data Delivery Standards.

Link:

OFAC Notice

This is the 26th annual report to Congress on terrorist assets frozen in the United States. There’s a table that shows that there is about $43.6 million in blocked assets under the Specially Designated Global Terrorist (SDGT), Specially Designated Terrorist (SDT) and Foreign Terrorist Organization (FTO) programs. Of that, about 14.5 million are assets of the Iranian Revolutionary Guards Corps (IRGC) Quds Force, 9.8 million are Hizballah assets, and 7.4 million are Al-Qaida assets.

There are also assets frozen related to state sponsors of terrorism, and those amounts dwarf the others – $201.53 million. Of that, Iranian assets represent more than half (104.5 million), with North Korea (63.4 million) and Syria (33.63 million) making up the rest. 

Link:

Terrorist Assets Report