Foreign Sanctions Evaders (FSE) List Updates

Because Kollmorgen’s Turkish affiliate serviced machines operating in Iran on six occasions, they agreed to a $13,381 settlement. At first glance, it appears that Kollmorgen knew its responsibilities:

Kollmorgen acquired control of Elsim in early 2013, thereby making Elsim subject to the ITSR’s prohibitions for any activity or conduct engaged in by Elsim, including conduct or activity occurring outside of the United States. Prior to the acquisition, Kollmorgen hired an external law firm and an external auditing and consulting company to perform sanctions due diligence on Elsim. The due diligence results demonstrated that Elsim made sales to, and had customers in, Iran prior to its acquisition by Kollmorgen. Based on these results, Kollmorgen determined it would need to take steps to prevent such sales from occurring in the future and educate Elsim on the applicability of U.S. sanctions.

Kollmorgen subsequently implemented a wide range of pre- and post-acquisition compliance measures designed to ensure Elsim complied with U.S. sanctions, which included but were not limited to the following:

(i) conducting a comprehensive review of Elsim’s customer database in order to identify any sales or customers located in, or with connections to, countries or regions subject to U.S. economic and trade sanctions;

Kollmorgen acquired control of Elsim in early 2013, thereby making Elsim subject to the ITSR’s prohibitions for any activity or conduct engaged in by Elsim, including conduct or activity occurring outside of the United States. Prior to the acquisition, Kollmorgen hired an external law firm and an external auditing and consulting company to perform sanctions due diligence on Elsim. The due diligence results demonstrated that Elsim made sales to, and had customers in, Iran prior to its acquisition by Kollmorgen. Based on these results, Kollmorgen determined it would need to take steps to prevent such sales from occurring in the future and educate Elsim on the applicability of U.S. sanctions.

Kollmorgen subsequently implemented a wide range of pre- and post-acquisition compliance measures designed to ensure Elsim complied with U.S. sanctions, which included but were not limited to the following:

(i) conducting a comprehensive review of Elsim’s customer database in order to identify any sales or customers located in, or with connections to, countries or regions subject to U.S. economic and trade sanctions;

However, apparently the Turkish affiliate not only ignored their obligations, but management “threatened to fire employees if they refused to travel to Iran”. Management also directed the employees to falsify their trips as vacation. Meanwhile, the affiliate was falsely certifying to Kollmorgen that they were not selling to Iran.

In October 2015, a whistleblower at the Turkish firm notified Kollmorgen of what was going on. The Turkish firm, however, tried to obstruct Kollmorgen’s investigation in a number of ways. Kollmorgen investigated and disclosed to OFAC.

Additionally, these are the remedial actions Kollmorgen then took:

(i) terminating the Elsim managers responsible for, and involved in, the Apparent Violations;

(ii) implementing new procedures to educate Elsim employees on compliance with U.S. economic and trade sanctions;

(iii) requiring Elsim to seek pre-approval from an officer based outside of Turkey for all foreign after-sales service trips; and

(iv) requiring Elsim to inform its major Turkish customers that Elsim cannot provide goods or services to Iran.

However, OFAC decided to penalize the parent company, despite its oversight and prompt remediation and its being misled by the Turkish affiliate:

Notwithstanding Kollmorgen’s extensive compliance efforts, OFAC determined a penalty was the appropriate administrative response to the Apparent Violations due to Elsim’s egregious conduct and specific risk profile, including that Elsim had previously engaged in business with Iran. Additionally, as described in detail below, the conduct of Elsim management and their subsequent attempts to impede Kollmorgen’s internal investigation warranted further action by OFAC.

The non-egregious, voluntarily self-reported violations carried a statutory maximum of $1,500,000 (for 6 violations) and had a base penalty of $7434.

So, why was the penalty so much larger?

  • The settlement amount reflects OFAC’s consideration of the General Factors under OFAC’s Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A. OFAC determined the following to be aggravating factors:
    1. Elsim willfully provided goods and services to Iran in violation of the ITSR;
    2. Elsim management knew its employees were traveling to Iran to provide services and directed them to do so;
    3. Elsim management concealed the Apparent Violations from Kollmorgen and others by deleting and falsifying records as well as directing their subordinates to do so; and
    4. the Apparent Violations conferred economic benefit to Iran.

    OFAC determined the following to be mitigating factors:

    1. neither Kollmorgen nor Elsim have received a penalty notice or finding of violation from OFAC in the five years preceding the earliest apparent violation;
    2. Kollmorgen cooperated with OFAC by conducting an effective and extensive internal investigation and submitting a comprehensive voluntary self-disclosure to OFAC; and, as described in detail above,
    3. Kollmorgen’s extensive preventative and remedial conduct. If OFAC had determined this case was egregious, the base civil monetary penalty amount for the Apparent Violations would have been $750,000.

    And the moral of the story?

    This case highlights the importance of: (1) performing heightened due diligence, particularly with regard to affiliates, subsidiaries, or counter-parties known to transact with OFAC- sanctioned countries or persons, or that otherwise pose high-risks due to their geographic location, customers and/or suppliers, or products and services they offer; and (2) implementing proactive controls when U.S. persons, directly or indirectly, acquire companies with preexisting relationships with sanctioned persons and jurisdictions.

    As noted in a separate post, the manager primarily responsible for the violations and the obstruction of the Kollmorgen investigation has been placed on the Foreign Sanctions Evaders (FSE) List.

    Still, Mr. Watchlist wonders if Kollmorgen hasn’t been made an example of. It’s pretty clear they tried to do the right thing, after the acquisition and when notified of the violations. Perhaps if the base penalty had been much larger, thre resultant settlement might not have larger than the base.

    Links:

    OFAC Notice

    OFAC Enforcement Information

    Yesterday, OFAC added:

    KAYAKIRAN, Evren, Turkey; DOB 08 Feb 1980; citizen Turkey; Gender Male; Passport U00242309 (Turkey) (individual) [FSE-IR].

    to their Foreign Sanctions Evaders (FSE) List. This is the first new listing since 2014.

    And Treasury issued the following press release:

    Treasury Sanctions Turkish National as Foreign Sanctions Evader Due To Repeated Violations of U.S. Sanctions Against Iran

    Action marks first time OFAC has named an individual a Foreign Sanctions Evader in relation to a civil enforcement action

    WASHINGTON – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took unprecedented action to concurrently designate a foreign sanctions evader and announce a directly related settlement with a U.S. company.  OFAC sanctioned a Turkey-based individual, Evren Kayakiran, who directed a foreign subsidiary of a U.S. company to violate U.S. sanctions against Iran and then attempted to conceal those violations. 

    “Treasury is sanctioning Kayakiran not just for his willful violation of U.S. sanctions on Iran, but also for directing staff to commit and cover up these illegal acts.  This is the first time that OFAC has designated an individual as a Foreign Sanctions Evader while resolving an enforcement matter, and is a marked change to how we will counter these acts of deception,” said Sigal Mandelker, Treasury Under Secretary for Terrorism and Financial Intelligence.  “This action is a clear warning that anyone in supervisory or managerial positions who directs staff to provide services, falsify records, commit fraud, or obstruct an investigation into sanctions violations exposes themselves to serious personal risk.”  

    Kayakiran is being sanctioned as a foreign sanctions evader pursuant to Executive Order 13608, which targets efforts by foreign persons to engage in activities intended to evade U.S. economic and financial sanctions with respect to Iran and Syria.  The Foreign Sanctions Evaders list (FSE List) is separate from OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List), and it identifies foreign individuals and entities that have violated, attempted to violate, conspired to violate, or caused a violation of U.S. sanctions against Iran or Syria.  As a result of today’s action, all transactions or dealings, whether direct or indirect, involving Kayakiran, in or related to (i) any goods, services, or technology in or intended for the United States, or (ii) any goods, services, or technology provided by or to U.S. persons, wherever located, are prohibited.  U.S. financial institutions must reject payments involving Kayakiran.

    The concurrent settlement is in connection with a U.S. company’s civil liability for Kayakiran’s conduct.  The settlement highlights the importance of performing heightened due diligence when U.S. persons, directly or indirectly, acquire companies with preexisting relationships with sanctioned persons and jurisdictions.  It also identifies compliance measures the U.S. company took pre- and post-acquisition of a foreign company and specific remedial actions.

    OFAC sanctioned Kayakiran, a Turkish national, for causing six violations of U.S. sanctions against Iran.  Between July 2013 and July 2015, Kayakiran was the managing director of a Turkish company that imports, distributes, and installs motion control products (the “Turkish Company”).  In March 2013, a U.S. company (the “U.S. Company”) acquired the Turkish Company, thereby making the latter subject to the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR).  Specifically, section 560.215 of the ITSR prohibits foreign entities that are owned or controlled by a U.S. person (including entities) and established or maintained outside the United States from knowingly engaging in any transaction with the Government of Iran or any person subject to the jurisdiction of that government that would be prohibited by the ITSR if engaged in by a U.S. person or in the United States. 

    Before and after the acquisition, the U.S. Company undertook a wide range of proactive compliance measures designed to ensure that the newly acquired Turkish Company complied with U.S. sanctions, including those against Iran. 

    Despite the U.S. Company’s extensive efforts, for two years after the acquisition, Kayakiran — in his role as the managing director of the Turkish Company — directed employees to service machinery located in Iran.  Employees were threatened with termination if they refused to travel to Iran to provide the services, and upon returning from the trips, employees were directed to falsify corporate records by listing the travel as vacation rather than business.  Kayakiran also regularly and fraudulently certified to the U.S. Company that no products or services were being sent to Iran.  It was only after an employee filed an internal complaint with the U.S. Company via the company’s ethics hotline in late October 2015 that the violations and associated conduct came to light.  The U.S. Company subsequently investigated the matter. 

    Upon being notified of the U.S. Company’s internal investigation, Kayakiran attempted to obstruct the investigation by instructing the Turkish Company’s employees to delete references to Iran in company records and misled the U.S. Company’s attorneys.  Finally, Kayakiran attempted to delete emails related to Iran.

    The U.S. Company completed its internal investigation despite Kayakiran’s efforts and fully cooperated with OFAC’s investigation, including by filing a thorough voluntary self-disclosure with OFAC.

    The Enforcement Action will be posted separately.

    Links:

    OFAC Notice

    Treasury Press Release

    On Wednesday, the Office of Foreign Assets Control (OFAC) added the following persons to the Specially-Designated Nationals (SDN) list under the Syrian sanctions program:

    ABDULKARIM, Wael (a.k.a. ABDULKARIM, Mohammad Wael), Dubai, United Arab Emirates; DOB 1973; POB Damascus, Syria; nationality Syria; Managing Director, Pangates International Corp. Ltd.; General Manager, Pangates International Corp. Ltd.; Director, Abdulkarim Group (individual) [SYRIA] (Linked To: PANGATES INTERNATIONAL CORPORATION LIMITED; Linked To: ABDULKARIM GROUP).
    BARQAWI, Ahmad (a.k.a. AL-BARQAWI, Ahmad; a.k.a. BARQAWI, Ahmad Abed Allah; a.k.a. BARQAWI, Ahmad Abedallah; a.k.a. BARQAWI, Ahmed; a.k.a. “BARQAWI, Hamodeh”), Dubai, United Arab Emirates; DOB 1985; POB Damascus, Syria; General Manager, Pangates International Corp. Ltd.; General Manager, Maxima Middle East Trading Co. (individual) [SYRIA] (Linked To: PANGATES INTERNATIONAL CORPORATION LIMITED; Linked To: MAXIMA MIDDLE EAST TRADING CO.).
    BEKTAS, Halis; DOB 13 Feb 1966; citizen Switzerland; Passport X0906223 (Switzerland) (individual) [SYRIA] [FSE-SY].
    HOLLEBRAND, Alexander (a.k.a. HOLLEBRAND, Sander); DOB 20 Dec 1954; POB Netherlands (individual) [SYRIA] [FSE-SY].
    VAN MAZIJK, Paul; DOB 24 Jan 1958; Passport NSK7K05F4 (Netherlands) (individual) [SYRIA] [FSE-SY].

     

    and the following entities:

    ABDULKARIM GROUP (a.k.a. ABD-AL-KARIM GROUP; a.k.a. ALKARIM FOR TRADE & INDUSTRY L.L.C.; a.k.a. ALKARIM FOR TRADE AND INDUSTRY; a.k.a. MOHD. WAEL ABDULKARIM & PARTNERS CO.; a.k.a. WAEL ABDULKARIM AND PARTNERS), Abu Rumaneh, Ibn Al Haytham St., Besides Indian Embassy, Building No. 7, 1st Floor, Office No. 5, Damascus, Syria; Jaber Bin Hayan St. No. 162, Akkad & Sufi Bldg No. 1, 1st Floor, Damascus, Syria; P.O. Box 5797, Damascus, Syria; P.O. Box 30693, Damascus, Syria; Adra-Tal El Kordi Triangle PC, Damascus 30693, Syria; Riyad El Solh Street, Beirut 12347, Lebanon; Website abdulkarimgroup.com [SYRIA] (Linked To: PANGATES INTERNATIONAL CORPORATION LIMITED).
    BLUEMARINE SA (a.k.a. BLUE MARINE SHIPPING AGENCY S.A.; a.k.a. BLUEMARINE AG; a.k.a. BLUEMARINE LTD), Lindenstrasse 2, Baar 6340, Switzerland [SYRIA] [FSE-SY].
    MAXIMA MIDDLE EAST TRADING CO., P.O. Box 122925, Sharjah Airport International Free Zone, SAIF Lounge, Sharjah, United Arab Emirates; Suite 13, First Floor Oliaji Trade Centre, Francis Rachel Street, Victoria, Mahe, Seychelles [SYRIA] (Linked To: ABDULKARIM GROUP; Linked To: PANGATES INTERNATIONAL CORPORATION LIMITED).
    RIXO INTERNATIONAL TRADING LTD., Lindenstrasse 2, Baar 6340, Switzerland; Website http://www.rixointernational.com [SYRIA] [FSE-SY].
    SKIRRON HOLDING SA (a.k.a. SKIRRON HOLDING AG), Lindenstrasse 2, Baar 6340, Switzerland [SYRIA].
    STAROIL B.V. (a.k.a. STAROIL S.A.), Wilhelminastraat 43 A, Haarlem 2011 VK, Netherlands; 30 A Rte de Chene, Geneva 1208, Switzerland; Registration ID 819860578 (Netherlands); V.A.T. Number NL 819860578B01 (Netherlands); Commercial Registry Number 34311024 (Netherlands) [SYRIA] [FSE-SY].

    In additon, the following persons were added to the Foreign Sanctions Evaders (FSE) List:

    BEKTAS, Halis; DOB 13 Feb 1966; citizen Switzerland; Passport X0906223 (Switzerland) (individual) [SYRIA] [FSE-SY].

    HOLLEBRAND, Alexander (a.k.a. HOLLEBRAND, Sander); DOB 20 Dec 1954; POB Netherlands (individual) [SYRIA] [FSE-SY].

    VAN MAZIJK, Paul; DOB 24 Jan 1958; Passport NSK7K05F4 (Netherlands) (individual) [SYRIA] [FSE-SY].

    and the following entities:

    BLUEMARINE SA (a.k.a. BLUE MARINE SHIPPING AGENCY S.A.; a.k.a. BLUEMARINE AG; a.k.a. BLUEMARINE LTD), Lindenstrasse 2, Baar 6340, Switzerland [SYRIA] [FSE-SY].

    RIXO INTERNATIONAL TRADING LTD., Lindenstrasse 2, Baar 6340, Switzerland; Website http://www.rixointernational.com [SYRIA] [FSE-SY].

    STAROIL B.V. (a.k.a. STAROIL S.A.), Wilhelminastraat 43 A, Haarlem 2011 VK, Netherlands; 30 A Rte de Chene, Geneva 1208, Switzerland; Registration ID 819860578 (Netherlands); V.A.T. Number NL 819860578B01 (Netherlands); Commercial Registry Number 34311024 (Netherlands) [SYRIA] [FSE-SY].

    Link:

    OFAC Notice

     

    191. What does Executive Order 13608 “Prohibiting Certain Transactions with and Suspending Entry into the United States of Foreign Sanctions Evaders with Respect to Iran and Syria” do?

    This Executive Order gives Treasury new authorities. First, it strengthens Treasury’s ability to address behavior by foreign individuals and entities determined to have violated, attempted to violate, conspired to violate, or caused a violation of U.S. sanctions on Syria or Iran. This E.O. also gives Treasury the authority to impose sanctions on foreign persons who have facilitated deceptive transactions for or on behalf of persons subject to U.S. sanctions.

    Transactions by U.S. persons or within the United States involving persons sanctioned under this authority are prohibited, effectively cutting the listed persons off from the U.S. marketplace and financial system. By cutting off access to the U.S. marketplace and financial system to such sanctions evaders, Executive Order 13608 provides Treasury with a powerful tool to prevent and deter such behavior and to hold such persons accountable and to convince them to change their behavior. Publicly identifying such persons will also allow U.S. persons to avoid unwittingly engaging in transactions with identified foreign persons that may expose U.S. persons to the risk of sanctions violations. [05-01-2012]

    192. Why was this authority needed?

    Executive Order 13608 expands Treasury’s ability to address the behavior of foreign persons determined to have violated or attempted to violate U.S. sanctions on Syria or Iran, or to have facilitated deceptive transactions on behalf of persons subject to those sanctions, where the foreign person had no physical, financial, or other presence in the United States and did not submit to U.S. administrative proceedings. Treasury may use this authority where it appears that a foreign person violated U.S. sanctions on Iran or Syria but may not meet criteria for designation under existing Executive Orders. Executive Order 13608 will provide a means through which Treasury can limit the risk to U.S. commercial and financial systems posed by foreign persons determined to have violated U.S. sanctions on Iran or Syria, or to have engaged in deceptive transactions for or on behalf of persons subject to U.S. sanctions on Iran or Syria.

    Such a listing under Executive Order 13608 also provides Treasury with the capability to put the world on notice as to such foreign persons’ activity and the risk of similar future activity. Such identification will help prevent U.S. persons from unwittingly engaging in transactions with foreign persons that may pose a risk of sanctions violations. [05-01-2012]

    193. What are the repercussions of an individual or entity being identified under Executive Order 13608?

    If an individual or entity is made subject to sanctions under this authority, U.S. persons generally may no longer provide to or procure from such individual or entity any goods, services, or technology. From a practical standpoint, it means that the sanctioned individual or entity will be cut off from the U.S. commercial and financial systems. [05-01-2012]

    194. Are U.S. persons required to block the property of individuals and entities identified under Executive Order 13608?

    No. Identifications or listings under Executive Order 13608 do not block any assets. However, a U.S. person may not provide or procure goods or services, including financial services, or technology to or from a listed person without authorization from OFAC, unless the transaction is otherwise exempt from regulation under the International Emergency Economic Powers Act (e.g., certain travel-related transactions). [05-01-2012]

    336. How do I know whether a person is identified under E.O. 13608?

    Please refer to the Foreign Sanctions Evaders (FSE) List. [02-06-2014]

    195. I am a financial institution. What do I do if I receive a wire transfer involving a listed party?

    A U.S. financial institution must reject any wire transfer involving a listed person and file a report with OFAC within 10 days. [05-01-2012]

    196. I am a financial institution and I hold an account for a listed person. What do I do with the funds?

    The account is not blocked; however, it is restricted and you cannot allow it to be operated without authorization from OFAC. [05-01-2012]

    197. What are U.S. persons obligated to do with property of a person listed under Executive Order 13608?

    Property of a listed person is not blocked, but U.S. persons must have authorization from OFAC to provide or procure such property to or from a listed person, or to provide or procure services to or from a listed person in connection with such property. Additionally, wire transfers involving the assets of an Executive Order 13608-listed person must be rejected. [05-01-2012]

    198. May a U.S. person deal with an Executive Order 13608-listed person so long as the dealing does not involve Iran or Syria?

    No. U.S. persons are prohibited from all transactions or dealings described in Executive Order 13608 with persons listed under Executive Order 13608, unless authorized by OFAC or where the transaction is otherwise exempt from regulation under the International Emergency Economic Powers Act. [05-01-2012]

    199. How is an identification or listing under Executive Order 13608 different from a designation?

    Like a designation, a U.S. person is prohibited, unless authorized by OFAC or if the underlying transaction is exempt from regulation under the International Emergency Economic Powers Act, from dealing with an identified or listed person. Unlike a blocking designation, the property and the interests in property of a person listed under Executive Order 13608 are not blocked. [05-01-2012]

    200. How is this different from lists maintained by the Department of Commerce?

    Treasury’s authority under Executive Order 13608 has some similarities to Commerce’s authority under the Export Administration Regulations (“EAR”). Commerce may impose denial orders on persons (both foreign and U.S.) who have committed violations of the EAR or present an imminent risk of committing a violation. These individuals or organizations are listed on Commerce’s Denied Persons List. It is prohibited to deal with Denied Persons in any export transaction involving items (commodities, software, and technology) subject to the EAR. Treasury’s authority under Executive Order 13608 complements Commerce’s authority by addressing at least two types of sanctions violations that are outside the scope of the EAR. Specifically, Treasury may prohibit the provision of services (in addition to goods and technology) to or from identified or listed persons and Treasury may prohibit transactions or dealings involving goods and technology that are not subject to the EAR. However, unlike Commerce’s authority, Treasury’s authority to sanction or list an individual or entity under Executive Order 13608 may be implemented only with respect to foreign individuals or entities. [05-01-2012]

    201. May a U.S. person deal with a person listed under Executive Order 13608 in a transaction that was previously licensed by OFAC?

    No. U.S. persons cannot have any dealings with a person identified or listed under this Executive Order absent specific authorization from OFAC pursuant to the Executive Order 13608, unless the transaction is exempt from regulation under the International Emergency Economic Powers Act. [05-01-2012]

    202. What if the transaction is already underway?

    If a transaction is underway at the time of a listing, a U.S. person must cease dealing with the listed person and the U.S. person is prohibited from engaging in transactions or dealings in or related to any goods, services, or technology to or from the listed person, unless the transaction is exempt under the International Emergency Economic Powers Act, or until such time that OFAC authorizes the transactions pursuant to the Executive Order 13608. Additionally, if the transaction underway involves a wire transfer, a U.S. financial institution must reject it and file a report with OFAC within 10 days.

    Like all of its programs, OFAC has the authority under Executive Order 13608 to license transactions that are consistent with U.S. foreign policy. [05-01-2012]

    203. Can a U.S. person use a listed person to facilitate personal remittances to or from Iran or Syria?

    No. Without specific authorization from OFAC, U.S. persons cannot use a listed person to process personal remittances. [05-01-2012]

    204. Will Treasury pursue an enforcement action before identifying or listing a person pursuant to Executive Order 13608?

    The authorities granted under this Executive Order are in addition to current authorities that Treasury has to pursue an enforcement action for violations of U.S. law, and Treasury is not required to pursue a civil enforcement action prior to identifying or listing a person pursuant to Executive Order 13608. [05-01-2012]

    Here's the OFAC Notice, in its entirety:

    Identification of Foreign Sanctions Evaders and the Publication of a New Foreign Sanctions Evaders List

    Today, the Office of Foreign Assets Control (OFAC) is introducing the Foreign Sanctions Evaders List (FSE List) to identify foreign persons sanctioned under Executive Order (E.O.) 13608, “Prohibiting Certain Transactions With and Suspending Entry Into the United States of Foreign Sanctions Evaders With Respect to Iran and Syria.”
    This Foreign Sanctions Evaders List (“FSE List”) includes persons sanctioned pursuant to E.O. 13608 for engaging in conduct relating to the evasion of U.S. economic and financial sanctions with respect to Iran or Syria, which are identified, respectively, with the program tags [FSE-IR] and [FSE-SY]. U.S. persons are generally prohibited from all transactions or dealings, whether direct or indirect, involving persons identified on this FSE List in or related to any goods, services, or technology (1) in or intended for the United States, or (2) provided by or to United States persons, wherever located. As a result, transactions by U.S. persons or through the United States are prohibited if they involve the provision or procurement of goods or services, including financial services, or technology to or from a person on the FSE List without authorization from OFAC, unless the transaction is otherwise exempt from regulation under the International Emergency Economic Powers Act (e.g., certain travel-related transactions).
    E.O. 13608 does not require the blocking of property or interests in property, but persons sanctioned under E.O. 13608 may be persons whose property and interests in property are blocked pursuant to other authorities administered by OFAC. The FSE List entries for persons sanctioned under E.O. 13608 whose property and interests in property are blocked under other authorities include program tags for relevant blocking authorities (e.g., [ISA] or [EO13645]). Such persons are also presented in a segregated sub-section of the FSE List. (Separately, such persons are included on OFAC’s Specially Designated Nationals and Blocked Persons List with program tags for relevant blocking authorities, as well as for E.O. 13608.)
    The FSE List will be available in almost all of the same file formats as the SDN List. The layout of names on the FSE List will be identical to the layout of names on the SDN List. In addition, FSE List data files will follow existing SDN List data standards. FSE List files and data file specifications will be available on the FSE List page. The FSE List may also be accessed on OFAC’s ftp server (ofacftp.treas.gov) in the /fse_list directory. There is no predetermined timetable for when the FSE List will be updated. Names and other information will be added and removed as necessary and appropriate. You may sign up for email notifications for updates to the FSE List. Updates to the FSE List will also be published on the recent actions page of OFAC’s website and on the office’s RSS feed.

     

    And these are the initial listings on the FSE List:

    FARSOUDEH, Houshang (a.k.a. FARSOUDEH, Houshang Hossein; a.k.a. FARSOUDEH, Hushang); DOB 10 Oct 1968; POB Tehran, Iran; Passport H2726141 (Iran) (individual) [FSE-IR].
    HOSSEINPOUR, Houshang (a.k.a. HOSEIN-PUR, Houshang; a.k.a. HOSSEINPOUR, Houshang Shahali); DOB 21 Mar 1967; POB Tehran, Iran; Passport R17550559 (Iran) expires 11 Jul 2015 (individual) [FSE-IR].
    NAYEBI, Pourya (a.k.a. NAYEBI, Pourya Ali Asghar); DOB 25 Jul 1974; POB Tehran, Iran; Passport V11664675 (Iran) expires 07 Aug 2012 (individual) [FSE-IR].
    SOKOLENKO, Vitaly (a.k.a. SOKOLENKO, Vitalii; a.k.a. SOKOLENKO, Vitaliy); DOB 16 Jun 1968; Executive Order 13645 Determination – Material Support; Passport EH354160; alt. Passport P0329907; General Manager of Ferland Company Limited; . (individual) [FSE-IR] [EO13645] (Linked To: FERLAND COMPANY LIMITED). -to- SOKOLENKO, Vitaly (a.k.a. SOKOLENKO, Vitalii; a.k.a. SOKOLENKO, Vitaliy); DOB 16 Jun 1968; Executive Order 13645 Determination – Material Support; Passport EH354160; alt. Passport P0329907; General Manager of Ferland Company Limited (individual) [FSE-IR] [EO13645] (Linked To: FERLAND COMPANY LIMITED).
    CAUCASUS ENERGY (a.k.a. CAUCASUS ENERGY OF GEORGIA; a.k.a. LLC CAUCASUS ENERGY), Georgia; Registration ID 406075081 [FSE-IR].
    EUROPEAN OIL TRADERS (a.k.a. EUROPEAN OIL TRADERS SA), Kaiserstuhlerstrasse 81, 8175, Windlach, Switzerland; 8174 Stadel b., Niederglatt, Switzerland [FSE-IR].
    GEORGIAN BUSINESS DEVELOPMENT (a.k.a. GBD FIZ; a.k.a. GBD FIZ LIMITED; a.k.a. GBD FIZ, LLC), Tbilisi, Georgia; Plot 545, Unit 1B-8D, Free Industrial Zone, Poti, Georgia; Deira, Dubai, United Arab Emirates [FSE-IR].
    GREAT BUSINESS DEALS, Tbilisi, Georgia; Plot 545, Unit 1B-8D, Free Industrial Zone, Poti, Georgia; Deira, Dubai, United Arab Emirates [FSE-IR].
    KSN FOUNDATION, Muehleholz 3, Vaduz 94490, Liechtenstein [FSE-IR].
    NEW YORK GENERAL TRADING (a.k.a. “NYGT”), No. 815, Al Maktoum Building, Al Maktoum St, P.O. Box 42108,, Deira, Dubai, United Arab Emirates; Registration ID 547066 [FSE-IR].
    NEW YORK MONEY EXCHANGE (a.k.a. “NYME”), P.O. Box 85334, Dubai, United Arab Emirates; Shop 14, Al MM Tower, Al Maktoum St, Dubai, United Arab Emirates; P.O. Box 31138, Abu Dhabi, United Arab Emirates; P.O. Box 42108, Dubai, United Arab Emirates; 20 Rustaveli Avenue, Tbilisi, Georgia; Tbilisi International Airport, Tbilisi, Georgia; Batumi Airport, Batumi, Georgia; Commercial Registry Number 549905 (United Arab Emirates) [FSE-IR].
    ORCHIDEA GULF TRADING (a.k.a. ORCHIDEA GULF EXCHANGE TRADING CO L; a.k.a. ORCHIDEA GULF TRADING ALTIN VE KIYMELTI MADENLER DIS TIC LTD STI; a.k.a. “ORCHIDEA GENERAL TRADING LLC”; a.k.a. “ORCHIDEA GULF COAST TRADING CO L”), P.O. Box 11254, Dubai, United Arab Emirates; P.O. Box 11254, 6305 Zinath Omar Kin Khatab,, Dubai, United Arab Emirates; P.O. Box 11256 Zinath Omar Kin Khatab, Dubai, United Arab Emirates; P.O. Box 6305 Zinath Omar Kin Khatab, Dubai, United Arab Emirates; P.O. Box 85334, Dubai, United Arab Emirates; P.O. Box 85334, Office Number 605, Concord Hotel, Al Matoum Street, Dubai, United Arab Emirates; Molla Gurani Mahallesi Sehit Pilot Nedim Sok. Evirgenler Ish, 5/5, Istanbul, Turkey [FSE-IR].
    FERLAND COMPANY LIMITED (a.k.a. FERLAND CO. LTD), 29 A Anna Komnini St., PO Box 2303, Nicosia, Cyprus; 5/7 Sabaneyev Most., Odessa, Ukraine [ISA] [FSE-IR]. -to- FERLAND COMPANY LIMITED (a.k.a. FERLAND CO. LTD), 29 A Anna Komnini St., PO Box 2303, Nicosia, Cyprus; 5/7 Sabaneyev Most., Odessa, Ukraine; Executive Order 13645 Determination – Material Support [ISA] [FSE-IR] [EO13645] (Linked To: NATIONAL IRANIAN TANKER COMPANY).

     

    Note that Ferland Company is also on the SDN List, and has a code of FSE-IR to denote its inclusion on the FSE List.

    Links to various forms of the FSE List, and the most recent changes document, have been added to the Watchlists page.

    The FSE List page has the list in many, many formats. The Watchlists page lists only the PDF, Text and XML versions, for simplicity.

    Links:

    OFAC Notice

    Executive Order 13608

    FSE List Page

    FSE FAQs

    Guidance on Alias Screening for the FSE and SDN Lists

    FSE and SDN Program Tags

     

    On Thursday, OFAC added the following persons and entities:

    AFKHAMI RASHIDI, Mahmud (a.k.a. AFKHAMI RASHIDI, Mahmood; a.k.a. AFKHAMI RASHIDI, Mahmoud); DOB 31 Aug 1962; POB Mashhad, Iran; nationality Iran; Passport D9005625 issued 11 Jul 2009 expires 11 Jul 2014 (individual) [SDGT] [IFSR].
    CANKO, Ali; DOB 01 Jan 1960; nationality Turkey; Additional Sanctions Information – Subject to Secondary Sanctions; Passport U 04765836 (Turkey); Personal ID Card58786069032; alt. Personal ID Card AK 8136255 (Italy) (individual) [NPWMD] [IFSR].
    HEMMATI, Alireza; DOB Dec 1955 (individual) [SDGT] [IFSR].
    ISHAQ, Malik (a.k.a. ISHAQ, Malik Mohammed; a.k.a. ISHAQ, Mohammed), Pakistan; DOB 1958; nationality Pakistan (individual) [SDGT].
    KOSARAYANIFARD, Pejman Mahmood (a.k.a. CASARYANIFARD, Pejman; a.k.a. KOSARAYAN FARD, Ali Pejman Mahmud; f.k.a. KOSARIAN FARD; a.k.a. KOSARIAN FARD, Pejman; a.k.a. KOSARIAN, Amir; a.k.a. KOSARYANI-FARD, Pejman), P.O. Box 52404, Dubai, United Arab Emirates; DOB 27 Feb 1973; Passport C20423657 (individual) [SDGT].
    MAHMOUDI, Gholamreza (a.k.a. MAHMOUDI, Gholam Reza; a.k.a. MAHMOUDI, Ghulam Reza Khodrat; a.k.a. MAHMUDI, Qolam Reza); DOB 03 Feb 1958; nationality Iran; Passport 5659068 (individual) [SDGT].
    MALEKOUTI POUR, Hamidreza (a.k.a. MALAKOTIPOUR, Hamid Reza; a.k.a. MALAKOTIPOUR, Hamidreza; a.k.a. MALAKOUTIPOUR, Hamid Reza; a.k.a. MALAKUTIPUR, Hamid Reza; a.k.a. MALKOTIPOUR, Hamid Reza); DOB 18 Oct 1960; Passport B5660433 (Iran) (individual) [SDGT].
    MUSAVI, Sayyed Kamal (a.k.a. JAMALI, Sayyed Kamal); DOB 03 Jan 1958 (individual) [SDGT] [IFSR].
    PUNTI, Pere (a.k.a. SANE, Pedro Punti); DOB 27 Aug 1944; nationality Spain; Additional Sanctions Information – Subject to Secondary Sanctions; Passport AAD225212 (Spain) expires 12 May 2020 (individual) [NPWMD] [IFSR].
    SADIKOV, Olimzhon Adkhamovich (a.k.a. AL-UZBEK, Jaffar; a.k.a. AL-UZBEKI, Jafar; a.k.a. MUHIDINOV, Jafar; a.k.a. MUIDINOV, Dilshod Alimovich; a.k.a. MUIDINOV, Djafar; a.k.a. MUIDINOV, Jafar); DOB 01 Jan 1977 to 31 Dec 1985; nationality Uzbekistan (individual) [SDGT].
    SEYED ALHOSSEINI, Akbar (a.k.a. SAEED HUSAINI, Akbar; a.k.a. SAYED ALHOSSEINI, Akbar; a.k.a. SAYEDOLHUSSEINI, Akbar; a.k.a. SAYYED AL-HOSEINI, Akbar; a.k.a. SEYEDOLHOSEINI, Akbar); DOB 22 Nov 1961; POB Taybad, Iran; Passport D9004309 issued 12 Nov 2008 expires 13 Nov 2013 (individual) [SDGT] [IFSR].
    WIPPERMANN, Ulrich; DOB 02 May 1956; Additional Sanctions Information – Subject to Secondary Sanctions; Member of the Board of Directors, DF Deutsche Forfait Aktiengesellschaft (individual) [NPWMD] [IFSR] (Linked To: DF DEUTSCHE FORFAIT AKTIENGESELLSCHAFT).
    ADVANCE ELECTRICAL AND INDUSTRIAL TECHNOLOGIES SL (a.k.a. CLEAR TRADE LINK SL; a.k.a. “AEIT”), Passeig Verdauguer, 120, Igualada (Barcelona) 08700, Spain; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR].
    AVIA TRUST FZE, P.O. Box 54541, Dubai, United Arab Emirates [SDGT].
    BLUE SKY AVIATION CO FZE, Al Maktoum Street, al Dana Centre, 3rd Floor, Office No. 306, Dubai, United Arab Emirates [SDGT].
    DF DEUTSCHE FORFAIT AKTIENGESELLSCHAFT (a.k.a. DEUTSCHE FORFAIT), Kattenbug 18 – 24, Koln, Nordrhein-Westfalen 50667, Germany; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR].
    DF DEUTSCHE FORFAIT AMERICAS INC., Miami, FL; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR].
    TIVA DARYA, Number 3, 12 Narenjestan Street, Pasdaran Avenue, Tehran, Iran; Bushehr, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR].
    TIVA KARA CO. LTD. (a.k.a. TIVA KARA GROUP), 3rd Floor, Block No. 3, North Pasdaran Street, 12th Narenjestan Alley, Before Aghdasie T-Junction Aqdaseya Saraya, Tehran, Iran; Number 3, 12th Narenjestan Alley, Pasdaran Avenue, Tehran, Iran; Miyaneh, Iran; Bushehr, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR].
    TIVA POLYMER CO., Number 3, 12th Narenjestan Street, Pasdaran Avenue, Tehran, Iran; Miyaneh, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR].
    TIVA SANAT GROUP (a.k.a. TIVA GROUP; a.k.a. TIVA GROUP INDUSTRIES; a.k.a. TIVA SANAT SHIPBUILDING COMPANY), Alley 10 and 3/10, No. 10, Behrestan Street, Sajad Boulevard, Mashhad, Iran; Number 4, 11th Narenjestan, Pasdaran Avenue, Tehran, Iran; Number 3, 12th Narenjestan, Pasdaran, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Registration ID 878 [NPWMD] [IFSR].

    As you can see, some of the listings are under the Iranian Financial Sanctions Regulations (IFSR), some are under the Non-proliferation of Weapons of Mass Destruction (NPWMD) and some are Specially-Designated Global Terrorists (SDGT) – and some are listed under multiple regimes. And that's why Mr. Watchlist did not scissor up the list.

    In addition, the following listing was updated:

    FERLAND COMPANY LIMITED (a.k.a. FERLAND CO. LTD), 29 A Anna Komnini St., PO Box 2303, Nicosia, Cyprus; 5/7 Sabaneyev Most., Odessa, Ukraine [ISA] [FSE-IR]. -to- FERLAND COMPANY LIMITED (a.k.a. FERLAND CO. LTD), 29 A Anna Komnini St., PO Box 2303, Nicosia, Cyprus; 5/7 Sabaneyev Most., Odessa, Ukraine; Executive Order 13645 Determination – Material Support [ISA] [FSE-IR] [EO13645] (Linked To: NATIONAL IRANIAN TANKER COMPANY).

    Ferland Company Limited is sanctioned under the Iran Sanctions Act (ISA) and is on the Foreign Sanctions Evaders list for aiding Iran (FSE-IR).

    In case you don't recognize the FSE list, don't despair – it was a new one to Mr. Watchlist, too. There'll be a post or two about it tomorrow – the list was updated today, too.

    Links:

    OFAC Notice