Terrorism

Earlier today, Swiss authorities amended the listing of:

SSID: 10-39773 Foreign identifier: QDi.419 Name: Anjem Choudary

DOB: 18 Jan 1967 POB: Welling, London, United Kingdom Low quality a.k.a.: Abu Luqman Address: Frankland PrisonLondon, United Kingdom Nationality: United Kingdom Identification document: Passport No. 516384722, United Kingdom, Date of issue: 6 May 2013, Expiry date: 6 Jun 2023 (issued by Passport Office Glasgow)

Relation: Pledged allegiance to Al-Qaida in Iraq (QE.J.115.04., SSID 10-17311) Other information: Pledged allegiance to Islamic State in Iraq and the Levant (ISIL), listed as Al- Qaida in Iraq (SSID 10-17311) in Jul 2014. Imprisoned in the United Kingdom in Sep 2014 with a tentative releaseand subsequently released on licence in Oct 20182018 which expires in Jul 2021. INTERPOL-UN Security Council Special Notice available. Modifications: Listed on 15 Oct 2018, amended on 11 Oct 2019

under its bin Laden/Al-Qaida/Taliban counter terrorism sanctions program.

Here is FINMA’s notice:

News

15 October 2019 

Financial sanction

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 11 October 2019, the relevant UN Sanctions Committee amended the list of persons, companies and organizations sanctioned in this context. The change is directly applicable in Switzerland. Therefore, on 14 October 2019, SECO adjusted the Swiss sanctions database SESAM (SECO Sanctions Management), which was relevant 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.

Links:

FINMA Notice

Data files of updates – PDF, XML

Today (Australia time), DFAT amended the following UN ISIL (Da’esh) and Al-Qaida Sanctions Committee listing:

QDi.419 Name: 1: ANJEM 2: CHOUDARY 3: na 4: na

Title: na Designation: na DOB: 18 Jan. 1967 POB: Welling, London, United Kingdom of Great Britain and Northern Ireland Good quality a.k.a.: na Low quality a.k.a.: Abu Luqman Nationality: United Kingdom of Great Britain and Northern Ireland Passport no: United Kingdom of Great Britain and Northern Ireland number 516384722, issued on 6 May 2013 (issued by Passport Office Glasgow, expires 06 Jun. 2023) National identification no: na Address: Frankland Prison, London, United Kingdom of Great Britain and Northern Ireland Listed on: 15 Oct. 2018 (amended on 11 Oct. 2019) Other information: Pledged allegiance to Islamic State in Iraq and the Levant (ISIL), listed as Al-Qaida in Iraq (QDe.115) in July 2014. Imprisoned in the United Kingdom in September 2014 with a tentative release in October 2018 and subsequently released on licence in October 2018 which expires in July 2021. INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals click here

Link:

UN Notice

Yesterday, OFAC added the following persons to the SDN List under its Global Magnitsky human rights sanctions program:

ESSA, Salim (a.k.a. ESSA, Salim Aziz), Johannesburg, South Africa; DOB 15 Jan 1978; nationality South Africa; Gender Male; Passport M00073786 (South Africa) issued 09 Nov 2012 expires 08 Nov 2022; National ID No. 7801155017084 (South Africa) (individual) [GLOMAG]. 

 

GUPTA, Ajay (a.k.a. GUPTA, Ajay Kumar), Dubai, United Arab Emirates; DOB 05 Feb 1966; POB Saharanpur, India; nationality India; Gender Male (individual) [GLOMAG]. 

 

GUPTA, Atul (a.k.a. GUPTA, Atul Kumar), Dubai, United Arab Emirates; DOB 14 Jun 1968; POB Saharanpur, India; nationality South Africa; Gender Male (individual) [GLOMAG]. 

 

GUPTA, Rajesh (a.k.a. GUPTA, Rajesh Kumar; a.k.a. “GUPTA, Tony”), Dubai, United Arab Emirates; DOB 05 Aug 1972; POB Saharanpur, India; nationality South Africa; Gender Male; National ID No. 7208056345087 (South Africa) (individual) [GLOMAG].

and changed the following 2 listings under the Iran (both), counter terrorism and/or non-proliferation programs (1 each):

BAHMAN GROUP, No. 37, Saba Boulevard, Africa Street, P.O. Box 14335-835, Tehran 1917773844, Iran; Website http://www.bahmangroup.com; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: ANDISHEH MEHVARAN INVESTMENT COMPANY). -to- BAHMAN GROUP, No. 37, Saba Boulevard, Africa Street, P.O. Box 14335-835, Tehran 1917773844, Iran; Website http://www.bahmangroup.com; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 

 

ROSTAMIAN, Kambiz, Villa No 13, Cluster 31 Juemierah Islands, Dubai, United Arab Emirates; DOB 27 Aug 1960; Additional Sanctions Information – Subject to Secondary Sanctions; Passport RE0003026 (Saint Kitts and Nevis); alt. Passport I17217816 (Iran) (individual) [NPWMD] [IFSR]. -to- ROSTAMIAN, Kambiz, Villa No 13, Cluster 31 Juemierah Islands, Dubai, United Arab Emirates; DOB 27 Aug 1960; Additional Sanctions Information – Subject to Secondary Sanctions; Passport RE0003028 (Saint Kitts and Nevis); alt. Passport I17217816 (Iran) (individual) [NPWMD] [IFSR].  

And Treasury:

PRESS RELEASES

Treasury Sanctions Members of a Significant Corruption Network in South Africa 

Global Magnitsky designations target members of family business engaged in corruption, including bribery and misappropriation of state assets

Washington – Today, the U.S. Department of the Treasury’s Office of Foreign AssetsControl (OFAC) sanctioned members of a significant corruption network in South Africa that leveraged overpayments on government contracts, bribery, and other corrupt acts to fund political contributions and influence government actions.  Specifically, OFAC designated Ajay Gupta, Atul Gupta, Rajesh Gupta, and Salim Essa for their involvement in corruption in South Africa pursuant to Executive Order (E.O.) 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act.

“The Gupta family leveraged its political connections to engage in widespread corruption and bribery, capture government contracts, and misappropriate state assets.  Treasury’s designation targets the Guptas’ pay-to-play political patronage, which was orchestrated at the expense of the South African people,” said Sigal Mandelker, Treasury Under Secretary for Terrorism and Financial Intelligence.  “The Guptas and Essa have used their influence with prominent politicians and parties to line their pockets with ill-gotten gains.  We will continue to exclude from the U.S. financial system those who profit from corruption.”

Today’s sanctions announcement demonstrates the U.S. government’s unwavering commitment to supporting the rule of law and accountability in South Africa.  We support the anti-corruption efforts of South Africa’s independent judiciary, law enforcement agencies, and the ongoing judicial commissions of inquiry.  Moreover, we commend the extraordinary work by South Africa’s civil society activists, investigative journalists, and whistleblowers, who have exposed the breadth and depth of the Gupta family’s corruption. 

THE GUPTA FAMILY

Ajay, Atul, and Rajesh Gupta immigrated to South Africa in the 1990s, and due in large part to their generous donations to a political party and their reportedly close relationship with former South African President Jacob Zuma, their business interests expanded.  The family has been implicated in several corrupt schemes in South Africa, allegedly stealing hundreds of millions of dollars through illegal deals with the South African government, obfuscated by a shadowy network of shell companies and associates linked to the family.  

Credible reports of these corruption schemes include the Gupta family offering members of the South African government money or elevated positions within the government, in return for their cooperation with Gupta family business efforts.  Public reporting has revealed Gupta family efforts to garner the cooperation of a potential Minister of Finance by promising millions of dollars in return for the individual’s assistance in removing key members of the South African government who were considered to be stumbling blocks to the Gupta family’s enterprises.  In another instance of an attempt to obtain the assistance of a member of government through illicit means, Rajesh reportedly promised a cut of a large scale development project to a provincial minister in return for the minister’s assistance.  While making this offer, Rajesh reportedly referred to two other politically powerful individuals present at the meeting as receiving large monthly payments, similar to the one being offered the provincial minister, directly from Rajesh in return for their assistance with a mining project.  In addition, the Gupta family was overpaid for government contracts and then used a portion of the proceeds of those overpayments to donate money to a South African political party.  Further, the family paid money to a South African government official in exchange for the appointment of other government officials friendly to the Gupta family business interests.  As a part of their corrupt business enterprise, South African government officials and business executives discussed ways to capture government contracts and then move the proceeds of those contracts through Gupta-owned businesses. 

AJAY GUPTA

Ajay Gupta (Ajay) is being designated for being the leader of an entity that has engaged in, or whose members have engaged in, corruption, including the misappropriation of state assets, the expropriation of private assets for personal gain, corruption related to government contracts or the extraction of natural resources, or bribery.

Ajay is the family patriarch who formulated the family’s corrupt business strategies and controlled its finances. 

ATUL GUPTA

Atul Gupta (Atul) has materially assisted, sponsored, or provided financial, material, technological support for, or goods or services to or in support of, an entity that has engaged in, or whose members have engaged in, corruption, including the misappropriation of state assets, the expropriation of private assets for personal gain, corruption related to government contracts or the extraction of natural resources, or bribery.

Atul is widely known to have overseen the Gupta family’s outreach to corrupt government officials.

RAJESH GUPTA

Rajesh Gupta (Rajesh) has materially assisted, sponsored, or provided financial, material, technological support for, or goods or services to or in support of, an entity that has engaged in, or whose members have engaged in, corruption, including the misappropriation of state assets, the expropriation of private assets for personal gain, corruption related to government contracts or the extraction of natural resources, or bribery.

Rajesh cultivated important relationships with the sons of powerful South African politicians and led efforts to pursue business and relationships in a South African province where corruption was rampant.  Rajesh attempted to use at least one of those relationships to seek undue influence with additional members of a South African political party.

SALIM ESSA

Salim Essa, a business associate of the Gupta family, has materially assisted, sponsored, or provided financial, material, technological support for, or goods or services to or in support of, an entity that has engaged in, or whose members have engaged in, corruption, including the misappropriation of state assets, the expropriation of private assets for personal gain, corruption related to government contracts or the extraction of natural resources, or bribery. 

As a result of today’s action, all property and interests in property of the individuals named above, and of any entities that are owned, directly or indirectly, 50 percent or more by them, individually, or with other designated persons, that are in the United States or in the possession or control of U.S. persons, are blocked and must be reported to OFAC.  Unless authorized by a general or specific license issued by OFAC or otherwise exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.  In addition, any approval, financing, facilitation, or guarantee by a U.S. person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited by E.O. 13818 if performed by a U.S. person or within the United States would be prohibited.

GLOBAL MAGNITSKY

Building upon the Global Magnitsky Human Rights Accountability Act, on December 20, 2017, the President signed E.O. 13818, in which the President found that the prevalence of human rights abuse and corruption that have their source, in whole or in substantial part, outside the United States, had reached such scope and gravity that it threatens the stability of international political and economic systems.  Human rights abuse and corruption undermine the values that form an essential foundation of stable, secure, and functioning societies; have devastating impacts on individuals; weaken democratic institutions; degrade the rule of law; perpetuate violent conflicts; facilitate the activities of dangerous persons; and undermine economic markets.  The United States seeks to impose tangible and significant consequences on those who commit serious human rights abuse or engage in corruption, as well as to protect the financial system of the United States from abuse by these same persons. 

To date, the Department of the Treasury has designated 118 individuals and entities under E.O. 13818.  This figure is in addition to the numerous human rights- or corruption-related designations Treasury has issued under other various authorities.  In total, since January of 2017, Treasury has taken action against more than 680 individuals and entities engaged in activities related to, or directly involving, human rights abuse or corruption. 

and State:

Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned four individuals for corruption in South Africa pursuant to Executive Order 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act.  Specifically, OFAC designated Ajay Gupta, Atul Gupta, Rajesh Gupta, and Salim Essa for their involvement in corrupt schemes with government officials and employees in state-owned enterprises for their own personal gain.  As a result of today’s actions, any property, or interest in property, of those designated within U.S. jurisdiction is blocked.  Additionally, U.S. persons are generally prohibited from engaging in transactions with blocked persons, including entities owned or controlled by designated persons.

Today’s action demonstrates continued U.S. commitment to promoting transparency, accountability, and the rule of law globally.  We commend the critical role played by South Africa’s civil society activists, whistleblowers, and investigative journalists to shine the spotlight on the Gupta network’s elicitation of criminal abuse of public office and other acts of corruption, which have deterred investment and impeded South Africa’s economic growth.  The United States strongly supports ongoing efforts by the Government of South Africa, including its independent judiciary, judicial commissions of inquiry, and law enforcement agencies, to investigate and prosecute alleged instances of corruption.  Successfully prosecuting and deterring corruption is essential to building a future of accountable government that fosters economic growth and opportunity for all of South Africa’s citizens.

both issued press releases.

As you can see, although the Magnitsky sanctions program is ostensibly about human rights abuses, the “global” (i,e. Besides Russia) version includes corruption. Why not just a corruption program? Mr. Watchlist wonders…

Links:

OFAC Notice

Treasury Press Release

State Department Press Release

On Tuesday, UK regulators corrected 3 listings that had been made under the counter terrorism sanctions program under Council Implementing Regulation (EU) 2019/24. As per OFSI’s notice:

2. On 9 January 2019, OFSI published a Notice which outlined that 2 individuals and 1 entity had been added to the consolidated list.

3. The update to the consolidated list on 8 October 2019 completes the additional information sections for these listings. Details of this correction can be found in the Annex to this Notice.

4. Assadollah Asadi, Saeid Hashemi Moghadam and the Directorate for Internal Security of the Iranian Ministry for Intelligence and Security are all still subject to an asset freeze.

Here are the corrected listings – individual:

1. ASADI, Assadollah

DOB: 22/12/1971. POB: Tehran, Iran Nationality: Iranian Passport Details: Iranian diplomatic passport number: D9016657 Other Information: EU listing only Listed on: 09/01/2019 Last Updated: 09/01/2019 08/10/2019 Group ID: 13740.

2. HASHEMI MOGHADAM, Saeid

DOB: 06/08/1962. POB: Tehran, Iran Nationality: Iranian Passport Details: Passport number: D9016290, valid until 4.2.2019. Other Information: EU listing only Listed on: 09/01/2019 Last Updated: 09/01/2019 08/10/2019 Group ID: 13741.

and entity:

1. DIRECTORATE FOR INTERNAL SECURITY OF THE IRANIAN MINISTRY FOR INTELLIGENCE AND SECURITY

Other Information: EU listing only Listed on: 09/01/2019 Last Updated: 09/01/2019 08/10/2019 Group ID: 13742.

The only real difference being the “Other Information” information.

Links:

OFSI Notice

Council Implementing Regulation (EU) 2019/24

 

UNCLASSIFIED

 

Notice of Changes to the Consolidated List

 

United Nations Security Council resolution 1373

 

Following a statutory review pursuant to section 15A of the Charter of the United Nations Act 1945, the Minister for Foreign Affairs has declared that the listing of 12 entities/ individuals will continue to have effect for a further three years. The amended listing is set out in the following Gazette notice: (https://www.legislation.gov.au/Details/C2019G00862/Download)

 

This updated information has now been reflected in amendments to the Consolidated List. The updated Consolidated List can be downloaded from the following page:

 

http://dfat.gov.au/international-relations/security/sanctions/pages/consolidated-list.aspx

 

On Friday, OFAC added the following entities:

ETEMAD TEJARATE PARS CO., No. 101 Sohrevardi St., Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] (Linked To: MINISTRY OF DEFENSE AND ARMED FORCES LOGISTICS). 

 

NATIONAL DEVELOPMENT FUND OF IRAN (a.k.a. NATIONAL DEVELOPMENT FUND OF ISLAMIC REPUBLIC OF IRAN (Arabic: صندوق توسعه ملی جمهوری اسلامی ایران)), No. 25 Gandhi St., Building National Development Fund of Iran, Tehran 15176-55911, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE; Linked To: MINISTRY OF DEFENSE AND ARMED FORCES LOGISTICS).

to the Iran and/or counter terrorism programs. Also, the following record for the Central Bank was updated:

BANK MARKAZI JOMHOURI ISLAMI IRAN (a.k.a. BANK MARKAZI IRAN; a.k.a. CENTRAL BANK OF IRAN; a.k.a. CENTRAL BANK OF THE ISLAMIC REPUBLIC OF IRAN), PO Box 15875/7177, 144 Mirdamad Blvd, Tehran, Iran; 213 Ferdowsi Avenue, Tehran 11365, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN]. -to- BANK MARKAZI JOMHOURI ISLAMI IRAN (a.k.a. BANK MARKAZI IRAN; a.k.a. CENTRAL BANK OF IRAN; a.k.a. CENTRAL BANK OF THE ISLAMIC REPUBLIC OF IRAN (Arabic: بانک مرکزی جمهوری اسلامی ایران)), PO Box 15875/7177, 144 Mirdamad Blvd, Tehran, Iran; 213 Ferdowsi Avenue, Tehran 11365, Iran; Mirdamad Blvd, 144 – P.O. Box 15875/7/77, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN] [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE; Linked To: HIZBALLAH). 

 

And Treasury:

PRESS RELEASES

Treasury Sanctions Iran’s Central Bank and National Development Fund

Action targets major sources of funding for the regime’s proxies and terrorist arms, including the IRGC, the Qods Force, Hizballah and the Houthis

WASHINGTON- Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action against the Central Bank of Iran (CBI), the National Development Fund of Iran (NDF), and Etemad Tejarate Pars Co. under its counterterrorism authority, Executive Order (E.O.) 13224.  Iran’s Central Bank has provided billions of dollars to the Islamic Revolutionary Guards Corps (IRGC), its Qods Force (IRGC-QF) and its terrorist proxy, Hizballah.  Iran’s NDF, which is Iran’s sovereign wealth fund and whose board of trustees include Iran’s president, oil minister, and the governor of the Central Bank, has been a major source of foreign currency and funding for the IRGC-QF and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL).  Etemad Tejarate Pars, also designated today, is an Iran-based company that is used to conceal financial transfers for MODAFL’s military purchases, including funds originating from the NDF.

“Iran’s brazen attack against Saudi Arabia is unacceptable.  Treasury’s action targets a crucial funding mechanism that the Iranian regime uses to support its terrorist network, including the Qods Force, Hizballah, and other militants that spread terror and destabilize the region.  The United States will continue its maximum pressure campaign against Iran’s repressive regime, which attempts to achieve its revolutionary agenda through regional aggression while squandering the country’s oil proceeds,” said Treasury Secretary Steven T. Mnuchin.  “Iran’s Central Bank and the National Development Fund were ostensibly intended to safeguard the welfare of the Iranian people, but have been used instead by this corrupt regime to move Iran’s foreign currency reserves for terrorist proxies.”

“We are putting governments on notice that they are risking the integrity of their financial systems by continuing to work with the Iranian regime’s arm of terror finance, its Central Bank,” said Sigal Mandelker, Under Secretary for Terrorism and Financial Intelligence. “We will vigorously enforce our sanctions to cut off the Iranian regime’s funding of global terrorism and its domestic oppression of the Iranian people, who are the regime’s longest suffering victims.”

CENTRAL BANK OF IRAN FUNDS THE IRGC, ITS QODS FORCE AND HIZBALLAH

Today’s action targets the CBI for its financial support to the IRGC-QF and Hizballah.  In May 2018, OFAC designatedthe CBI’s then-Governor Valiollah Seif, and the Assistant Director of the International Department Ali Tarzali, for facilitating financial transfers for the IRGC-QF and Hizballah.  Also, in November 2018 and as part of Treasury’s disruption of an international oil-for-terror network, OFAC designated the CBI’s International Department Director Rasul Sajjad, and the CBI’s International Department Director, Hossein Yaghoobi, for conducting financial transactions for the IRGC-QF.

Since at least 2016, the IRGC-QF has received the vast majority of its foreign currency from the CBI and senior CBI officials have worked directly with the IRGC-QF to facilitate CBI’s financial support to the IRGC-QF. In 2017, the IRGC-QF oversaw the transfer of tens of millions of euros to Iraq from the CBI. Then-Governor of the CBI Valiollah Seif directed the transfer.

During 2018 and early 2019, the CBI facilitated the transfer of several billion of U.S. dollars and euros to the IRGC-QF and hundreds of millions to MODAFL from the NDF.  Additionally, millions were to be transferred to the Houthis. CBI has also coordinated with the IRGC-QF to transfer funds to Hizballah.

OFAC is designating the CBI today for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to, the IRGC-QF and Hizballah.

The IRGC-QF, which was designated pursuant to E.O. 13224 on October 25, 2007, is a branch of the IRGC responsible for external operations and has provided material support to numerous terrorist groups, including the Taliban, Hizballah, HAMAS, and the Palestinian Islamic Jihad, making it a key component of Iran’s destabilizing regional activities. The IRGC, including its external arm, the IRGC-QF, was designated as a Foreign Terrorist Organization on April 8, 2019.

Hizballah was designated by the Department of State as a Foreign Terrorist Organization in October 1997 pursuant to E.O. 13224 in October 2001.  It was also designated in August 2012 pursuant to E.O. 13582, which targets the Government of Syria and its supporters.

NATIONAL DEVELOPMENT FUND: A SLUSH FUND FOR THE IRGC-QF AND MODAFL

According to Article 84 of the Fifth Development Plan of the Islamic Republic of Iran, the NDF was established to serve the welfare of the Iranian people by allocating revenues that originated from selling oil, gas, gas condensate, and oil products to durable wealth and productive economic investments.  However, the NDF has been used as a slush fund for the IRGC-QF, which has, for years, received hundreds of millions of dollars in cash disbursements from the NDF.

The NDF, in coordination with the CBI, provided the IRGC-QF with half a billion U.S. dollars in 2017 and hundreds of millions of dollars in 2018. Also, despite an increase in the IRGC’s overall budget for 2019, the Rouhani administration withdrew some $4.8 billion from the NDF in January 2019 to amend the budget allocated to the IRGC and the Islamic Republic of Iran Broadcasting (IRIB).

The IRIB was designated pursuant to E.O. 13628 in February 2013 for assisting or denying the free flow of information to or from the Iranian people. IRIB was implicated in censoring multiple media outlets and airing forced confessions from detainees.   

During 2018 and early 2019, the CBI facilitated the transfer of hundreds of millions to both the Atomic Energy Organization and MODAFL from the NDF.  Some of the funds to be transferred via Iran-based Etemad Tejarate Pars Co. were intended to be used for military purchases.

As of early 2019, Etemad Tejarate Pars Co. planned to send tens of millions in various currencies, including euros, to Wilmington General Trading LLC in Dubai, UAE, the Embassy of the Islamic Republic of Iran in Moscow, Russia, and to companies on behalf of MODAFL.

OFAC is designating NDF for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to, the IRGC-QF and MODAFL.

OFAC is designating Etemad Tejarate Pars Co. for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to, MODAFL.

On March 26, 2019, OFAC designated MODAFL pursuant to E.O. 13224 for its role in assisting the IRGC-QF. Wilmington General Trading LLC was also designated on March 26, 2019 for being owned or controlled by Asadollah Seifi who obfuscated millions of dollars’ worth of transactions benefiting the Iranian regime and the purchase of foreign currency for the IRGC.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of these entities that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.  OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked or designated persons.

In addition, persons that engage in certain transactions with the entities designated today may themselves be exposed to designation.  Furthermore, any foreign financial institution that knowingly facilitates a significant financial transaction or provides significant financial services for entities designated in connection with Iran’s support for international terrorism or any Iranian person on OFAC’s List of Specially Designated Nationals and Blocked Persons could be subject to U.S. correspondent account or payable-through account sanctions.

The United States has a long standing policy of allowing for the sale of agricultural commodities, food, medicine and medical devices, and OFAC will continue to consider requests related to humanitarian trade with Iran as appropriate.

Identifying information on the entities designated today.

and State:

In a failed attempt to disrupt the global economy, the Islamic Republic of Iran attacked the Kingdom of Saudi Arabia. This act of aggression was sophisticated in its planning and brazen in its execution. Regardless of transparent attempts to shift blame, the evidence points to Iran—and only Iran. As a result, President Trump instructed his administration to substantially increase the already-historic sanctions on the world’s leading state sponsor of terrorism. Today, we have followed through on his direction.

The United States has sanctioned Iran’s Central Bank and its National Development Fund, as well as Etemad Tejarat Pars, an Iran-based company, which has been found to conceal financial transfers for military purchases. These entities support the regime’s terrorism and regional aggression by financing the Islamic Revolutionary Guard Corps, a designated Foreign Terrorist Organization, its Qods Force, and Hizballah, the Iranian regime’s chief proxy force.

Attacking other nations and disrupting the global economy has a price. The regime in Tehran must be held accountable through diplomatic isolation and economic pressure. Our campaign of maximum pressure will continue to raise costs on the Islamic Republic of Iran until it reverses its destabilizing policies across the Middle East and around the world.

issued press releases.

Somehow, Mr. Watchlist expected more – perhaps the US is running out of things to sanction.

Links:

OFAC Notice

Press Releases- Treasury, State

Yesterday, UK regulators renewed the Final Designations of:

1. EJERCITO DE LIBERACION NACIONAL (ELN)

a.k.a: National Liberation Army Other Information: Both UK listing and EU listing. Listed on: 02/11/2001 Last Updated: 09/10/2018 16/09/2019 Group ID: 7364.

2. SENDERO LUMINOSO (SL)

a.k.a: Shining Path Other Information: Both UK listing and EU listing. Listed on: 02/11/2001 Last Updated: 09/10/2018 16/09/2019 Group ID: 7440.

made under the Terrorist Asset Freezing etc Act 2010 (TAFA) for the statutory maximum of 1 year, or until revoked.

Link:

OFSI Notice