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These were both issued on August 8th, and were both Finding of Violations for not adhering to the Reporting, Procedures and Penalties Regulations (RPPR).

Here’s the DNI facts:

On May 29, 2015, OFAC issued an Administrative Subpoena to DNI to investigate its involvement in the facilitation of the shipment, supply, and sale of farm equipment to Sudan in apparent violation of the Sudanese Sanctions Regulations, 31 C.F.R. §§ 538.205, 538.206 (SSR).1 OFAC issued a Cautionary Letter to DNI for the underlying apparent violations of the SSR, but determined that DNI’s conduct in response to OFAC’s investigation warranted an administrative response.

On June 12, 2015, through its outside counsel, DNI responded to the administrative subpoena (“administrative subpoena response”). After reviewing DNI’s administrative subpoena response, OFAC determined that several of DNI’s responses to the administrative subpoena were contradictory, false, materially inaccurate, incomplete, and contained misleading statements.

On July 12, 2016, OFAC sent DNI’s outside counsel an e-mail (“administrative subpoena follow-up e-mail”), which, in part, requested clarification on DNI’s version of events and supporting documents that DNI had provided to OFAC in response to the administrative subpoena and also sought clarification from DNI about whether it understood its obligations under § 501.602 of the RPPR and § 538.205 of the SSR.

On July 21, 2016, DNI, through its outside counsel, responded to the administrative subpoena follow-up email. OFAC found DNI’s responses to the administrative subpoena follow-up email to be contradictory, false, materially inaccurate, incomplete, and misleading. DNI’s response also stated that it understood its obligations under § 501.602 of the RPPR and § 538.205 of the SSR. Additionally, DNI’s response to the administrative subpoena follow-up email introduced new information that was responsive to the original administrative subpoena, but was not included in the response to the original administrative subpoena.

And why OFAC decided on a Finding of Violation:

OFAC considered the following to be aggravating factors:

  1. DNI, through counsel, demonstrated reckless disregard for its U.S. sanctions requirements by failing to provide accurate and complete information in response to an OFAC Administrative Subpoena;
  2. DNI, and its owner, facilitated both the shipment and attempted shipment of goods to Sudan and provided financing for such shipments. Accordingly, DNI had actual knowledge that its responses to OFAC’s Administrative Subpoena concerning the facilitation of the shipment and attempted shipment of goods to Sudan and related financing were false, materially inaccurate, materially incomplete, and misleading;
  3. After supplying OFAC with responses that were false, materially inaccurate, materially incomplete, and misleading, OFAC gave DNI the opportunity to correct or clarify its original responses. However, DNI failed to appropriately amend its responses and instead confirmed its original responses; and
  4. By providing false, materially inaccurate, materially incomplete, and misleading statements, DNI did not fully cooperate with OFAC’s investigation.

OFAC found the following to be mitigating factors:

  1. DNI appears to be a small business;
  2. DNI has no prior OFAC sanctions history; and
  3. DNI’s narrative responses appear to have been filtered through DNI’s outside attorney.

And the lesson to be learned:

This enforcement action highlights the compliance obligations of persons subject to the RPPR, and the importance for all subject persons to furnish information to OFAC during the course of an investigation in a manner consistent with such obligations. Companies and individuals alike should be diligent in their review of information and documentation that may be responsive to an administrative subpoena issued by OFAC. A person’s response to an administrative subpoena must be accurate, complete, timely, and in accordance with sanctions regulations and definitions. As exhibited in this matter, failure to provide complete or accurate information to OFAC in response to an administrative subpoena constitutes a violation of the RPPR.

And Southern Cross’ behavior:

On June 27, 2016, OFAC issued an Administrative Subpoena and an accompanying letter to Southern Cross in which OFAC stated it had reason to believe that Southern Cross was recently involved in the sale of several helicopters destined for Iran via an Iranian businessman based in Ecuador (the “Iranian Businessman”). The Administrative Subpoena directed Southern Cross to provide detailed information, descriptions, and documents regarding any such transactions, as well as any other dealings with Iran during the prior five (5) years. On July 5, 2016, the President of Southern Cross sent an email to OFAC in which the company denied knowing or conducting any business with the Iranian Businessman or dealing with Iran in any way. On July 8, 2016, Southern Cross provided a written response to OFAC’s Administrative Subpoena in which Southern Cross claimed that a Southern Cross sales representative located in Ecuador (the “SC Ecuador Representative”) sent technical details to an Ecuadorian group for a potential sale of helicopters to an Iranian group for operation in Ecuador and provided no documentation to OFAC other than a copy of the company’s internal Export Management Manual.

On October 6, 2016, OFAC issued a second Administrative Subpoena to Southern Cross seeking similar information and documentation and specifically requesting certain documentation relating to the potential sale. In its October 11, 2016 response to OFAC’s second Administrative Subpoena, Southern Cross submitted correspondence relating to the potential sale, including direct email exchanges between the SC Ecuador Representative and the Iranian Businessman explicitly referenced in both of OFAC’s Administrative Subpoenas. The information and documentation submitted by Southern Cross also included: (i) email exchanges between the SC Representative and the Iranian Businessman in which they discussed a letter of intent and sale of helicopters to an agent in Iran; and (ii) email exchanges between the SC Representative and the Ecuadorian group in which they discussed the sale of two helicopters to the Iranian Businessman in greater detail, as well as a letter of intent from the Iranian Businessman in which he indicated the letters were from Iran. Southern Cross failed to produce this responsive information to OFAC’s first Administrative Subpoena.

And OFAC’s reasoning:

OFAC considered the following to be aggravating factors:

  1. Southern Cross demonstrated reckless disregard for its U.S. sanctions requirements by failing to provide accurate and complete information in response to an OFAC Administrative Subpoena;
  2. Southern Cross had actual knowledge or reason to know of the conduct that led to the violation in this instance; and
  3. Southern Cross did not fully cooperate with OFAC’s investigation.

OFAC found the following to be mitigating factors:

  1. Southern Cross appears to be a small-to- medium-sized business;
  2. Southern Cross has no prior OFAC sanctions history; and
  3. the underlying potential sale in question does not appear to have occurred.

And the lesson:

This enforcement action highlights the compliance obligation of persons subject to the RPPR, and the importance for all subject persons to cooperate with OFAC investigations. Companies and individuals alike should be diligent in their review of information and documentation that may be responsive to an Administrative Subpoena issued by OFAC. A person’s response to an Administrative Subpoena must be accurate, complete, and timely. As exhibited in this matter, failure to provide complete information to OFAC in response to an Administrative Subpoena constitutes a violation of the RPPR.

Links:

Enforcement Information: DNI Express, Southern Cross

Notice

Notice to exporters 2019/13: new control on exporting submersible vessels and related equipment to Russia

Published 14 August 2019

And the new control, issued under The Export Control (Amendment) (No. 2) Order 2019:

Submersible Vessels and related goods, software and technology
PL9012 The export or “transfer by electronic means” of the following goods, “software” or “technology” is prohibited to any destination in Russia:
a. ‘submersible vehicles’, and related systems, equipment and components, as follows, other than those specified in Schedule 2 to this Order or Annex I to “the dual-use Regulation”:
1. ‘submersible vehicles’ and specially designed components therefor;
2. Subsea ploughs and specially designed components therefor;
3. Systems, equipment and components for use with ‘submersible vehicles’ and subsea ploughs, as follows:
a. Marine acoustic systems and equipment, as follows:
i. sonar equipment;
ii. velocity log equipment;
iii. underwater altimeters;
b. Navigation equipment specially designed for ‘submersible vehicles’;
c. Acoustic systems and equipment designed to determine the position of ‘submersible vehicles’ including via surface vessels;
d. Propulsion motors or thrusters for ‘submersible vehicles’;
e. Umbilical cables and connectors therefor, specially designed or modified for ‘submersible vehicles’;
f. Umbilical winches, tow winches and lifting winches;
g. Tethers and tether systems, for ‘submersible vehicles’;
h. Lighting systems specially designed or modified for underwater use;
i. Underwater vision systems;
j. Underwater communication systems;
k. Pressure sensors specially designed for underwater use;
l. Launch and recovery systems and equipment for deploying ‘submersible vehicles’ and specially designed components therefor;
m. Trenching tools and jetting tools, specially designed or modified for use with ‘submersible vehicles’;
n. Control systems and equipment specially designed or modified for the remote operation of ‘submersible vehicles’;
o. Remotely controlled articulated manipulators specially designed or modified for use with ‘submersible vehicles’;
p. Subsea cable detection systems;
q. Cable cutting, clamping and handling equipment, specially designed or modified for use with ‘submersible vehicles’;
r. Subsea telecoms handling systems and equipment;
s. Tools specially designed or modified to be operated by ‘submersible vehicles’ or articulated manipulators;
t. Syntactic foam;
u. Pressure housings specially designed or modified for use on ‘submersible vehicles’;
v. Biological, chemical or physical environmental sensors designed or modified to be used underwater;
b. Azimuth adjustable propulsion systems for use in surface vessels with a propeller diameter of greater than 2m;
c. “Software” designed for the “development”, “production” or “use” of goods specified in PL9012.a. and PL9012.b.
d.

“Technology” for the “development”, “production” or “use” of goods or “software” specified in PL9012.a., PL9012.b. or PL9012.c.

N.B.: See article 18 of this Order for exceptions from the controls on “technology”.

Technical Note:

‘Submersible vehicles’ include manned, unmanned, tethered or untethered vehicles..

Link:

Notice to exporters 2019/13

Export Control (Amendment) (No. 2) Order 2019

The firm, which is in the truck business, agreed to a $1,709,325 settlement for 63 apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR), which were voluntarily self-disclosed and non-egregious violations. The base penalty is therefore $2,713,214 for selling $5,426,428 worth of products. The violations occurred between October 2013 and February 2015.

Here’s the “what” of what happened:

In June and October 2014, a DAF dealer based in Hamburg, Germany, placed two orders with DAF via its wholly owned subsidiary in Germany (“DAF Germany”) for 51 trucks. Even though the final paperwork associated with these transactions identified the ultimate end-customer as an unnamed party in Russia, the Hamburg-based dealer resold the trucks to a buyer in Iran. A former employee/manager of DAF Germany had, at a minimum, reason to know that the trucks were intended for Iran rather than for Russia. The Hamburg-based dealer initially requested a price quotation from, and then placed an order with, DAF Germany for trucks with particular specifications for an Iranian company located in Iran. The then-employee/manager of DAF Germany informed the Hamburg-based dealer that DAF Germany could not sell trucks destined for Iran. That same day, the Hamburg-based dealer submitted a pricing request for a new order of trucks purportedly destined for a customer or end-user in Russia with virtually identical specifications as the earlier order intended for Iran. Although the new pricing request was submitted on the same day on which DAF Germany refused the Iran-related purchase order and the proposed purchase involved the same types of trucks, with the same specifications, and the same delivery point as those included in the Iran-related purchase order, DAF Germany — including the former employee/manager — failed to conduct an adequate inquiry and processed the order.

Separately, DAF Trucks Frankfurt, a directly owned DAF dealer, received two trucks from DAF in October 2013 that were intended for resale to a company in Germany. After the original buyer cancelled the order, DAF Trucks Frankfurt sold the two trucks to a trader based in the Netherlands, which in turn resold the trucks to two buyers in Iran. DAF’s investigation showed that an employee of DAF Trucks Frankfurt knew or had reason to know that the two trucks sold to the Netherlands-based trader were intended for resale to buyers in Iran. Among other things, the Netherlands-based trader sent drafts of its invoices, which referenced the buyers in Iran, to a DAF Trucks Frankfurt employee.

Additionally, in June 2014, DAF sold 10 trucks to an authorized DAF sales dealer located in Sofia, Bulgaria. The Bulgarian authorized dealer subsequently sold and delivered the 10 DAF trucks to an affiliated rental company, which in turn sold the 10 trucks to a buyer in Iran. The Bulgarian authorized dealer’s parent company disclosed that a used truck sales manager employed by DAF introduced that authorized dealer to the Iranian buyers of the 10 trucks and knew or should have known that the trucks were intended for Iran prior to introducing the parties. A DAF investigation found that the sales manager ignored warning signs indicating the trucks were destined for Iran and failed to take reasonable steps in response to the warnings.

And OFAC considered the following factors in determining the penalty:

OFAC considered the following to be aggravating factors:

  1. DAF personnel — specifically, employees in DAF Germany and DAF Trucks Frankfurt and a DAF used trucks sales manager — failed to exercise a minimal degree of caution or care when they ignored warning signs regarding potential sales involving OFAC-sanctioned countries and allowed goods to be sold to customers that they knew or had reason to know intended to re-sell the goods to buyers in Iran;
  2. in each case, a DAF employee had knowledge or reason to know the goods were being re-sold to buyers in Iran;
  3. DAF’s exportation of goods from Germany to Iran conferred millions of dollars in economic benefits on Iran; and
  4. PACCAR, DAF’s parent company, is a large sophisticated entity that engages extensively in international business.

OFAC considered the following to be mitigating factors:

  1. neither PACCAR nor DAF have received a penalty notice or Finding of Violation from OFAC in the five years preceding the earliest date of the transactions giving rise to the apparent violations;
  2. at the time of the apparent violations, DAF possessed and maintained a trade sanctions compliance program that included contractual prohibitions on dealers and service partners re-selling DAF products in violation of U.S. trade sanctions;
  3. upon learning of the apparent violations, DAF took remedial action by conducting an internal investigation regarding this matter; terminating employees involved in some of the apparent violations; cancelling delivery of 20 trucks that were part of an order for a customer that appeared to have allowed other DAF trucks to be resold to buyers in Iran; providing in-person compliance training to DAF subsidiaries on an annual basis from 2015 onward; and implementing enhanced trade compliance controls — including a policy preventing direct sales agreements except for sales to final end customers — in an effort to prevent similar apparent violations from recurring; and
  4. PACCAR and DAF cooperated during the course of OFAC’s investigation, including by submitting a detailed voluntary self- disclosure; thoroughly and promptly responding to OFAC’s requests for information and by entering into a tolling agreement to extend the statute of limitations.

Some details on PACCAR’s remedial efforts:

Additionally, PACCAR and DAF have confirmed to OFAC that they have terminated the apparently violative conduct and have taken the following steps to minimize the risk of recurrence of similar conduct in the future:

• DAF hired a full-time Compliance Director who reports to DAF’s General Counsel and Chief Compliance Officer, and is responsible for developing compliance policies and procedures, advising employees about compliance, monitoring internal reports of compliance concerns and ensuring appropriate follow-up, and assisting with compliance investigations and audits;

• DAF updated its EU Trade Restrictions Compliance Manual to strengthen controls on dealer sales that might violate U.S. or other applicable trade restrictions, including by requiring more thorough end-customer and transaction due diligence;

• DAF implemented a policy that only allows direct sales agreements for sales to final end- customers and imposed a contractual ban on the resale of new trucks acquired under a direct sales agreement in the absence of an approved exception;

• DAF sent a letter to all dealers in its dealer network reminding them of their obligations to comply with U.S. and other trade sanctions and received certifications from each of its dealers regarding their compliance with all applicable trade sanctions; and

• DAF has made trade sanctions compliance training an annual requirement and has conducted such trainings at DAF’s headquarters and subsidiaries since 2016.

And the lesson you should learn from this:

This enforcement actions highlights the benefits U.S. companies can realize in conducting sanctions-related training and in taking appropriate steps to audit and monitor foreign subsidiaries for OFAC compliance. U.S. parent companies can mitigate risk to sanctions exposure by proactively establishing and enforcing a robust sanctions compliance program. Foreign subsidiaries of U.S. companies are subject to the ITSR, and their U.S. parent companies may face potential exposure to civil monetary penalties for the actions of such entities.

Link:

Enforcement Information

OFSI to update consolidated list links

In 3 weeks time, OFSI will launch a new consolidated list, the system it uses to publish the details of individuals and entities subject to financial sanctions.

The consolidated list extracts will have updated links on the gov.uk website. It is important that any bookmarks to the old links for each format are updated to the new links.

In addition to the existing five formats in which OFSI currently publishes the consolidated list (html, csv, xls, pdf and txt), it will now also be published as an .xml file. The files themselves will be updated as and when there are changes to the consolidated list and you will continue to be able to use the consolidated list as you do now.

There will also be a new search tool to help individuals and organisations identify targets of financial sanctions more easily. This allows users to quickly search the list of asset-freeze targets and the list of targets subject to restrictions on financial markets and services.

Further details will be published in the coming weeks. OFSI will be launching the new consolidated list on 30th August 2019. 

If you have any questions about this email, please contact us using the link below.

Earlier today, Swiss authorities updated 54 individuals listed under the Syrian sanctions program and delisted the following persons:

SSID: 200-12029 Name: Fahid Al-Jassim

Title: Lieutenant General Good quality a.k.a.: Fahd

Justification: Chief of Staff. Military official involved in the violence in Homs. Modifications: Amended on 6 Nov 2013, 19 Jan 2016, de-listed on 13 Aug 2019

SSID: 200-12084 Name: Ahmed Yousef Jarad

Title: Brigadier General Good quality a.k.a.: a) Ahmad b) Youssef c) Jarrad Justification: Ordered troops to shoot at protestors in Deraa, including the use of machine guns and anti-aircraft guns. Other information: Commander of 132nd Brigade. Modifications: Amended on 6 Nov 2013, 19 Jan 2016, de-listed on 13 Aug 2019

SSID: 200-12129 Name: Mohsin Makhlouf

Title: Brigadier General

Justification: Gave orders to troops to shoot at protestors in Al-Herak. Modifications: Amended on 6 Nov 2013, 19 Jan 2016, de-listed on 13 Aug 2019

SSID: 200-12142 Name: Suheil Salman Hassan

Title: Major General Good quality a.k.a.: Suhail

Justification: Gave orders to troops to shoot at the protesters in Deraa Governorate. Other information: Commander of 5th Division. Modifications: Amended on 6 Nov 2013, 19 Jan 2016, de-listed on 13 Aug 2019

SSID: 200-22423 Name: Omran Ahed Al Zu’bi

DOB: 27 Sep 1959 POB: Damascus, Syrian Arab Republic Good quality a.k.a.: Al Zoubi (Al Zo’bi, Al Zou’bi)

Justification: Former Minister of Information in power after May 2011. As a former Government Minister, shares responsibility for the regime’s violent repression against the civilian population. Modifications: Amended on 6 Nov 2013, 19 Jan 2016, 16 Jun 2017, de- listed on 13 Aug 2019

SSID: 200-22447 Name: Mohammad Turki Al Sayed

Justification: Former Minister of Industry. As a former Government Minister shares responsibility for the regime’s violent repression against the civilian population.

Modifications: Amended on 6 Nov 2013, 23 Jun 2014, 19 Jan 2016, de-listed on 13 Aug 2019

SSID: 200-30629 Name: Wael Abdulkarim

DOB: 30 Sep 1973 POB: Damascus, Syrian Arab Republic Good quality a.k.a.: Al Karim Address: Al Karim for Trade and Industry, P.O.Box 111, Damascus, 5797, Syrian Arab Republic

Justification: Leading businessperson operating in Syria in the oil, chemicals and manufacturing industries. Specifically, he represents Abdulkarim Group, a.k.a Al Karim Group/Alkarim for Trade and Industry/Al Karim Trading and Industry/Al Karim for Trade and Industry. Abdulkarim Group is a leading manufacturer of lubricants, greases and industrial chemicals in Syria. Relation: Represents Abdulkarim Group (SSID 200-29931) Other information: POB: Damascus, Syria (of Palestinian origin) Modifications: Listed on 18 Mar 2015, amended on 3 Jun 2015, 19 Jan 2016, 10 Jun 2016, 11 Oct 2016, de-listed on 13 Aug 2019

SSID: 200-36669 Name: Isam Zahr Al-Din

Title: Brigadier General DOB: 1961 POB: Tarba, As-Suwayda province, Syrian Arab Republic Good quality a.k.a.: a) Issam (Essam) b) Zuhair (Zaher) c) Eldin (al-Deen) d) Isam Zohruddin e) Issam Zahruddin f) Issam Zahreddine g) Essam Zahruddin h) Nafed Assadllah

Justification: Holds the rank of Brigadier General, a senior officer in the Republican Guard, in post after May 2011. As a senior military officer he is responsible for the violent repression against the civilian population, including during the siege of Baba Amr in February 2012. Modifications: Listed on 3 Aug 2017, amended on 3 Oct 2017, de-listed on 13 Aug 2019

and entities:

SSID: 200-12600 Name: Drex Technologies Holding S.A.

Address: 17, rue Beaumont, Luxembourg, L-1219 (formerly established at this address) Justification: The beneficial owner of Drex Technologies Holding S.A. is Rami Makhlouf, already subject to sanctions for providing financial support to the Syrian regime. Relation: Beneficial owner is Rami Makhlouf (SSID 200-11672) Other information: Registered in Luxembourg under number B77616. Modifications: Amended on 19 Jan 2016, de-listed on 13 Aug 2019

SSID: 200-29931 Name: Abdulkarim Group

Good quality a.k.a.: a) Al Karim for Trade and Industry b) Al Karim Group Address: Damascus, 5797

Justification: Abdulkarim Group is an internationally recognised Syrian conglomerate that is associated with Wael Abdulkarim, who is listed as a leading businessperson operating in Syria. Relation: Associated with Wael Abdulkarim (SSID 200-30629) Modifications: Listed on 17 Dec 2014, amended on 20 Jul 2017, de-listed on 13 Aug 2019

SSID: 200-30737 Name: DK Group

Good quality a.k.a.: a) DK Group Sarl b) DK Middle East & Africa Regional Office Address: a) DK Middle East & Africa Regional Office, Peres Lazaristes Center, No. 3, 5th Floor, Emir Bachir Street, Beirut Central District, Bachoura Sector, Beirut, Lebanon b) Azarieh Building – Block 03, 5th Floor, Beirut, Lebanon c) Azarieh Street – Solidere – Downtown, P.O.Box 11-503, Beirut, Lebanon

Justification: a) DK Group supplies new banknotes to the Central Bank of Syria. b) DK Group therefore provides support to the regime. Due to this supply relationship, it is also associated with a designated entity, the Central Bank of Syria. Relation: Supplier Central Bank of Syria (SSID 200-12534, supplies new banknotes to the Central Bank of Syria) Modifications: Listed on 18 Mar 2015, amended on 19 Jan 2016, de-listed on 13 Aug 2019

Here is the FINMA Notice:

Updated sanction message

The Federal Department of Economic Affairs, Education and Research WBF has published an amendment to Annex 7 of the Ordinance of 8 June 2012 on Measures against Syria (SR 946.231.172.7).

On 12 August 2019, the Federal Department of Economic Affairs, Education and Research WBF amended the list of persons, companies and organizations sanctioned in this context. The change is directly applicable in Switzerland. The WBF has therefore adjusted the Swiss sanctions database SESAM (SECO Sanctions Management), which is relevant for Switzerland, and published the adaptation on its website . The change will take effect on August 13, 2019 at 6:00 pm.

 

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

FOR IMMEDIATE RELEASE
  August 9, 2019
  Contact: DEA Public Affairs
 

Press Release

 

Lebanese businessman tied by Treasury Department to Hezbollah is sentenced to prison for money laundering scheme involving the evasion of U.S. sanctions

 

WASHINGTON – The operator of a network of businesses in Lebanon and Africa, whom the United States Department of the Treasury designated as a financier of Lebanon-based terrorist group Hezbollah, was sentenced to five years in prison and ordered to forfeit $50 million by U.S. District Judge Reggie B. Walton of the District of Columbia.

 

Kassim Tajideen, 63, had previously pleaded guilty to one count of conspiracy to launder monetary instruments in furtherance of violating the International Emergency Economic Powers Act (IEEPA). In 2009, the U.S. Department of the Treasury designated Tajideen as a Specially Designated Global Terrorist based on his tens of millions of dollars of financial support of Hezbollah. The designation prohibited Tajideen from being involved in, or benefiting from, transactions involving U.S. persons or companies without a license from the Department of the Treasury.

 

“This defendant knowingly violated sanctions and put our nation’s security at risk,” said Assistant Attorney General Brian A. Benczkowski of the Criminal Division.  “His sentencing and the $50 million forfeiture in this case are just the latest public examples of the Department of Justice’s ongoing efforts to disrupt and dismantle Hezbollah and its support networks.”

 

Tajideen’s case falls under the United States Drug Enforcement Administration’s Project Cassandra, which targets Hezbollah’s global criminal support network, which operates as a logistics, procurement and financing arm for Hezbollah. This investigation and others are part of the Department of Justice’s Hezbollah Financing and Narcoterrorism Team. The HFNT was formed in January 2018 to ensure an aggressive and coordinated approach to prosecutions and investigations, including Project Cassandra cases, targeting the individuals and networks supporting Hezbollah. Comprised of experienced international narcotics trafficking, terrorism, organized crime, and money laundering prosecutors and investigators, the HFNT works closely with partners like the DEA, the Department of the Treasury, and the Federal Bureau of Investigation, among others, to advance and facilitate prosecutions of Hezbollah and its support network in appropriate cases.

 

“This is the latest example of the DEA’s success against Hezbollah’s global criminal support network and our commitment to interagency collaboration in combatting the overall threat posed by this transnational criminal organization,” said Acting Special Agent in Charge of DEA’s Special Operations Division Michael J. Machak.

 

“Today’s sentencing highlights our efforts to prosecute those who violate sanctions meant to stem the flow of money to terrorists groups,” said U.S. Attorney Jessie K. Liu for the District of Columbia. “Our message to those who violate sanctions is that you will be found, and you will be prosecuted to the full extent of the law.”

 

According to the statement of facts signed by Tajideen in conjunction with his plea, after his designation, Tajideen conspired with at least five other persons to conduct over $50 million in transactions with U.S. businesses that violated these prohibitions. In addition, Tajideen and his co-conspirators knowingly engaged in transactions outside of the United States, which involved transmissions of as much as $1 billion through the United States financial system from places outside the United States.

 

This case was investigated by DEA SOD’s Counter Narcoterrorism Operations Center and the DEA New Jersey Field Division, with support from the Customs and Border Protection’s National Targeting Center/Counter Network Division, the U.S. Treasury Department’s Financial Crimes Enforcement Network and Office of Foreign Assets Control, the Criminal Division’s Office of International Affairs, and the Counterintelligence and Export Control Section of the National Security Division.

 

The case was prosecuted by Trial Attorney Joseph Palazzo of the Money Laundering and Asset Recovery Section and Assistant U.S. Attorneys Thomas A. Gillice, Luke Jones, Karen Seifert and Deborah Curtis and Special Assistant U.S. Attorney Jacqueline L. Barkett of the U.S. Attorney’s Office for the District of Columbia.

FOR IMMEDIATE RELEASE
July 23, 2019
Contact: Bryan Hubbard
(202) 649-6870
 

OCC Issues Consent Order of Prohibition and $50,000 Civil Money Penalty Against Former General Counsel of Rabobank N.A.

WASHINGTON—The Office of the Comptroller of the Currency (OCC) today announced the issuance of a consent order of prohibition and $50,000 civil money penalty against Daniel Weiss, the former General Counsel of Rabobank, N.A., Roseville, Calif. (Bank).

The consent order prohibits Mr. Weiss from participating in the affairs of any federally insured depository institution and assesses a $50,000 civil money penalty for violations of law and unsafe or unsound practices alleged in the notice of charges (notice) issued on March 25, 2019.

The notice alleges that Daniel Weiss, as General Counsel of the Bank, participated in the continuous concealment of a third party report assessing the Bank’s Bank Secrecy Act program from the OCC in violation of 12 USC 481 and made false statements to the OCC in violation of 18 USC 1001.

On February 7, 2018, the Bank pled guilty to conspiracy to obstruct an OCC examination in violation of 18 USC 371 and 1517 in the U.S. District Court in the Southern District of California, and agreed to pay a forfeiture in the amount of $368,701,259 and a civil money penalty to the OCC in the amount of $50 million, based in part on the violation of 12 USC 481.

Links:

OCC Notice

Consent Order

Notice of Charges