Sanctions Regulations
They're listed under the UK, since this is where I found them. Obviously, the EU/EC regulations are applicable to all of the European Union. Included are 4 set of regs: Terrorist Asset-Freezing etc. Act 2010 Al-Qaida (Asset-Freezing) Regulations 2011 Council Regulation (EC) No 2580/2001 Council Regulation (EC) No 881/2002 I'll […]
The Watchlists, Licenses and Regulatory Links pages have been updated: The Licenses page has updated links for the 5 General Licenses for the terrorism sanctions, as well as a link to the page where they all are (because of the nice synopsis of the 5 on that page) The Watchlist […]
The new page has nice, short descriptions of the 5 General Licenses. Rather than rephrase them… Provision of insurance policies to designated persons This licence allows insurers (including a broker, underwriter or intermediary) to issue an insurance policy of any description to a designated person. Insurers are required to report […]
The National Defense Authorization Act of 2013 (NDAA), dated January 2nd of this year, includes the Iran Freedom and Counter-Proliferation Act (IFCA) in its Subtitle D. It's bigger than a breadbox (yes, Mr. Watchlist will write a post or two explaining it), so here are just the section listings of […]
P is also for Penalties – in particular, this covers the penalties for violations under the Trading with the Enemy Act… This part of the RPPR is from 31 CFR 501.701-747 (aka “Subpart D”). Sections 704 through 747 deal with the minutiae of the hearing process, and won't be covered […]
My friend at OFAC confirmed, off the record, of course, that the statutory maximum civil penalty for the Kingpin Act is still $1,075,000. So, I whipped out my browser and my calculator and did the math. In June 2002, the CPI-U (used for calculating the adjustment) was, according to the […]
If you don't recognize that figure, it's the oft-quoted maximum civil monetary penalty per violation of the Foreign Narcotics Kingpin Designation Act (FNKDA or “Kingpin Act”). It's such a strange number – and yet, so explainable. The Federal Civil Penalties Inflation Adjustment Act of 1990, finally implemented in 2003, stipulates […]
P is for procedures… this is a lengthy section of the RPPR, so running this down in bullet form seems best… Licensing Specific licenses must be applied for by mail or courier, not electronically or by FAX. Applications to unblock funds transfers must use Form TD-F 90-22.54; other license applications […]
The Reporting, Procedures and Penalties Regulations (RPPR) is a queer duck (it's an expression – get used to it). It has three distinct, albeit loosely related sections: reporting and recordkeeping, general rules and procedures for changes made to sanctions regimes, and penalties under the Trading with the Enemy Act (TWEA), […]
Mr. Watchlist 