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Notice to Exporters 2019/08: 3 open general licences updated

Published 4 June 2019


Notice to Exporters 2019/08

Open General Trade Control Licence (maritime anti-piracy)

Open General Export Licence (export after exhibition of demonstration: military goods)

Open General Export Licence (Iraq)

On Thursday, OFAC issued amended versions of Venezuela General Licenses 7, 8 and 13. General Licenses 8 and 13 were extended through July 27th, while section a of General License 7 “automatically renews on the first day of each month, and is valued for a period of 18 months from the effective date of General License No. 7B or the date of any subsequent renewal of General License No. 7B, whichever is later.”

Mr. Watchlist does not understand this – if it is valid for 18 months, why does it need to renew each month?

Also, the authorization in section b said it is valid through April 28th, which has already passed. Was this a mistake, or did they mean 2020 (or some other date)?

OFAC also issued a single new, unrelated FAQ:

672. Can I export or reexport diluents to Venezuela? 

No.  Diluents (including, for example, crude oil and naphtha) play a key role in the transportation and exportation of Venezuelan petroleum, a primary source of revenue for the illegitimate and corrupt Maduro regime, which the United States seeks to restrict further.  OFAC is amending General Licenses (GLs) 7A, 8, and 13  effective as of June 6, 2019, to restrict U.S. persons engaging in transactions and activities authorized by those GLs from exporting or reexporting diluents, directly or indirectly, to Venezuela, or from engaging in transactions or activities related thereto. 


Absent authorization from OFAC, all U.S. persons continue to be prohibited from engaging in any dealings with Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest.  In addition, non-U.S. persons could be subject to designation pursuant to Executive Order 13850, as amended, for operating within the oil sector of the Venezuelan economy, or for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of PdVSA, including the exportation or reexportation of diluents to PdVSA.  


Given PdVSA’s role as Venezuela’s state-owned oil company, exports or reexports of diluents to Venezuela likely include a direct or indirect interest of PdVSA.  As a result, persons directly or indirectly exporting or reexporting diluents to Venezuela should exercise enhanced due diligence to verify the ultimate end user and ensure that the transaction does not involve a direct or indirect interest of a sanctioned person, including PdVSA, even if the sanctioned person is not identified as a participant in the transaction. [06-06-2019] 


OFAC Notice

General License 7B

General License 8A

General License 13A

FAQ 672

Today, OFSI (part of HM Treasury) posted a new short document (4 pages including the cover image) about what sanctions on Russia will look like after the UK exits the European Union.

There are sections on asset freezes, transferable securities or money-market instruments (listing specific restricted firms), loan and credit arrangements, and Crimea-related investments. (If it cut and pasted better, I would post it, but…).


OFSI guidance


EU Notice


5.1 Screening of customers11 should be carried out against relevant ML/TF information sources, which include designated names of individuals and/or entities within:

(a) the lists and information provided by the Authority or other relevant authorities in Singapore in relation to ML/TF risks;

(b) the First Schedule of the TSOFA; and

(c) the MAS TFS Regulations.

5.2 In the context of direct insurance business, the screening of customers should include the screening of policy owners, insureds and claimants. In cases where an insurer has assessed the policy owner or insured to be of a higher ML/TF risk, the insurer should also screen the substantial shareholders (direct and indirect), beneficial owners, natural persons appointed to act on behalf of the customer and directors, if any, of the policy owner or insured.

5.3 In the context of reinsurance business, the screening of customers should include the screening of cedants and claimants12. Underlying insureds should also be screened in cases where they are made known to the reinsurers. In cases where a reinsurer has assessed the cedant or underlying insured to be of a higher ML/TF risk, the reinsurer should also screen the substantial shareholders (direct and indirect), beneficial owners and directors, if any, of the cedant or underlying insured.

5.4 Screening of customers should be conducted at the following points in time:

(a) before establishing business relations for new customers, otherwise as soon as reasonably practicable thereafter;

(b) prior to renewing business relations with existing customers;

(c) on a regular basis after the establishment of business relations13;

(d) when there are changes made to the lists14 mentioned in paragraph 5.1 above;


(e) before making claim payments to claimants15.

5.5 For the purposes of screening, the insurer should minimally, either:

(a) subscribe to a commercial sanctions database; or

(b) maintain an internal database containing the names of designated individuals

and entities.

5.6 The screening database(s) (i.e. commercial sanctions database and/or internally-

maintained database) and procedures adopted by an insurer should be effective in identifying individuals and entities with adverse information, as well as designated individuals and entities as defined in the First Schedule of the TSOFA and the MAS TFS Regulations, or as informed by the relevant authorities in Singapore.

5.7 In view of system limitations in screening capability, some insurers may not be able to effectively detect designated individuals or entities if they were to perform screening based on a full/exact match logic instead of a partial/fuzzy16 match logic for name searches. A full/exact name match for screening should not be used, as this will likely result in missed sanctions or adverse comments hits. In addition, the screening filters used by the insurer should not be limiting17 and should take into account the various permutations of a person’s first and last names.

5.8 Insurers are reminded that where screening results in a positive hit against the lists mentioned in paragraph 5.1, an insurer shall freeze without delay and without prior notice, the funds or other assets of designated persons and entities that it has control over, so as to comply with applicable laws and regulations in Singapore. This would include both the TSOFA and the MAS TFS Regulations relating to sanctions and freezing of assets of persons. Any such assets shall be reported promptly to the relevant authorities and an STR shall be filed.

5.9 Insurers should also have in place screening procedures when hiring employees, officers18 and agents19, and when establishing business relationships with offshore intermediaries. This should include, where applicable:


(a) background checks with past employers;

(b) credit history checks;

(c) screening against ML/TF information sources; and

(d) bankruptcy searches.

Subject: Counterfeit Cashier’s Checks

Date: May 22, 2019

Description: Farmers & Merchants National Bank


Counterfeit Cashier’s Checks of Farmers & Merchants National Bank, Nashville, Ill.

To: Chief Executive Officers of All National Banks and Federal Savings Associations; All State Banking Authorities; Chair, Board of Governors of the Federal Reserve System; Chair, Federal Deposit Insurance Corporation; Conference of State Bank Supervisors; Deputy Comptrollers (Districts); Assistant Deputy Comptrollers; District Counsels; and All Examining Personnel

The above-named bank has reported that counterfeit cashier’s checks using the bank’s routing number of 081906275are being presented for payment nationwide in connection with a variety of online auction and job opportunity scams.

There are at least four variations of counterfeit checks in circulation. While the counterfeit checks resemble the bank’s authentic items, they may be identified by the following traits:

Variation #1

  • The checks are light blue with a white wreath in the center and contain a darker blue border.
  • The bank’s logo does not contain the telephone number.
  • The following security statement is located along the right border along with a padlock icon: “Security features included. Details on back.”
  • A heat sensitive hologram security feature appears in the bottom center portion of the check.
  • The authorized signature appears as “Anna Wilhelm.”
  • The remitter name may be “Mark Rilay.”

Variation #2

  • The checks are light blue with a darker blue top and bottom border.
  • The top border contains the following security statement: “THE FACE OF THIS DOCUMENT HAS A COLORED BACKGROUND ON WHITE PAPER.”
  • The bank’s logo does not contain the telephone number.
  • The bottom border contains the following security statement: “THE BACK OF THIS DOCUMENT CONTAINS CHECK SECURITY WATERMARK AND COIN REACTIVE INK.”
  • A heat sensitive key security feature is located in the bottom center portion of the check.
  • The authorized signature appears as “Anna Wilhelm.”
  • The remitter name may be “John Nowicki.”

Variation #3

  • The checks are white and contain the following security statement in blue in the top border: “WARNING: THIS DOCUMENT HAS SECURITY FEATURES IN THE PAPER.”
  • The bank’s logo does not contain the telephone number.
  • A padlock icon and security statement appear along the right border.
  • The authorized signature appears as “Anna Wilhelm.”
  • The remitter name may be “Janeen Glasco.”

Variation #4

  • The checks are of unknown color but contain a marbled background and darker top border.
  • The bank’s logo does not contain the telephone number.
  • The authorized signature appears as “Anna Wilhelm.”
  • The remitter name may be “Cody Miller.”

Checks presented to date have been made payable in amounts between $1,450 and $6,850.

For additional information and to verify the authenticity of cashier’s checks drawn on Farmers & Merchants National Bank, please contact Chief Financial Officer Kimberly Gill by mail at 120 West St. Louis Street, Nashville, IL 62263, by telephone at (618) 327-2405, by fax at (618) 327-4963, or by email at

Consumers who receive counterfeit or fictitious items and associated material should file complaints with the following agencies, as appropriate:

  • U.S. Department of the Treasury, Office of Inspector General (OIG): by telephone at (800) 359‑3898 or by visiting the OIG website.
  • Federal Trade Commission (FTC): by telephone at (877) FTC-HELP or, for filing a complaint electronically, via the FTC’s website.
  • National Consumers League (NCL): by telephone at (202) 835-3323 or by email. To file a fraud complaint, visit the NCL fraud website.
  • Better Business Bureau (BBB): The BBB system serves markets throughout Canada, Puerto Rico, and the United States and is the marketplace leader in advancing trust between businesses and consumers. The website offers contact information for local BBBs, objective reports on more than 2 million businesses, consumer scam alerts, and tips on a wide variety of topics that help consumers find trustworthy businesses and make wise purchasing decisions.
  • Federal Bureau of Investigation Internet Crime Complaint Center (to report scams that may have originated via the internet).
  • If correspondence is received via the U.S. Postal Service, contact the U.S. Postal Inspection Service by telephone at (888) 877-7644; by mail at U.S. Postal Inspection Service, Office of Inspector General, Operations Support Group, 222 S. Riverside Plaza, Suite 1250, Chicago, IL 60606-6100; or via the online complaint form.

Additional information concerning this matter that should be brought to the attention of the Office of the Comptroller of the Currency (OCC) may be forwarded to

Office of the Comptroller of the Currency

Special Supervision Division
400 7th St. SW, Suite 3E-218; MS 8E-12
Washington, DC 20219

Phone: (202) 649-6450

Fax: (571) 293-4925

For additional information regarding other types of financial fraud, please visit the OCC’s anti-fraud resources page.


Monica A. Freas

Director for Enforcement and Compliance


OCC Notice


Office of Public Affairs


Tuesday, June 4, 2019

Two Indictments Unsealed Charging Iranian Citizen with Violating U.S. Export Laws and Sanctions against Iran

Peyman Amiri Larijani, 33, a citizen of Iran and former resident of Istanbul, Turkey, was charged in the United States District Court for the District of Columbia in two separate indictments.  The announcement was made by Assistant Attorney General for National Security John C. Demers, U.S. Attorney Jessie K. Liu for the District of Columbia and Assistant Secretary Nazak Nikakhtar of the U.S. Department of Commerce.

A 34-count indictment returned on April 22, 2015, charges Larijani and a Turkish based company, Kral Havacilik IC VE DIS Ticaret Sirketi (Kral Aviation), with conspiracy to acquire U.S. origin aircraft parts and goods to supply to entities and end-users in Iran, to conceal from United States companies and the U.S. government that the U.S.-origin goods were destined for Iranian aviation business end users, to make financial profit for defendants and other conspirators, and to evade the regulations, prohibitions, and licensing requirements of the International Emergency Economic Powers Act (IEEPA), the Iranian Transactions and Sanctions Regulations (ITSR), and the Export Administration Regulations (EAR).

“The Department is committed to vigorous enforcement of the sanctions placed on Iran for its oppressive and destabilizing behavior,” said Assistant Attorney General Demers.  “The indictment charges the defendant with conspiring to equip an Iranian airline that has been designated for supporting the Islamic Revolutionary Guard Corp, a key instrument of the Iranian regime’s belligerent activity.  Sanctions evasion weakens the power of sanctions to change Iran’s behavior and makes us all less safe.”

“Our export laws are in place to prevent the shipment of goods to hostile countries and to keep items out of the hands of people who intend to harm the United States,” said U.S. Attorney Jessie K. Liu.  “We will continue to aggressively prosecute those who violate our export control laws to protect the national security of the United States.”

“The Trump Administration will apply maximum pressure on Iran to end its promotion of instability and terrorism worldwide,” said Assistant Secretary Nikakhtar.  “Mahan Air represents a continuing significant threat against United States and its allies.  We will use all of the tools at our disposal to bring to justice those who threaten our way of life and violate our laws.”

According to the indictment, beginning around December 2010 through July 2012, Larijani was the Operations Manager for Kral Aviation.  Larijani and his co-conspirators purchased U.S.-origin aircraft parts and accessories from U.S. companies.  Larijani and his co-conspirators wired money to banks in the United States as payment for these parts and concealed from U.S. sellers the ultimate end use and end users of the purchased parts.  Larijani and his co-conspirators caused these parts to be exported from the United States to Istanbul, Turkey, before shipping to airlines in Iran including Mahan Air, Sahand Air, and Kish Air.

Mahan Air has been designated by the U.S. Department of the Treasury as a Specially Designated National (SDN) for providing financial, material and technological support to Iran’s Islamic Revolutionary Guard Corps-Qods Force.  The Department of Commerce has placed Mahan on its Denied Parties List and Kral Aviation on the Entity List.

On March 15, 1995, the President, pursuant to IEEPA, issued Executive Order No. 12957, finding that “the actions and policies of the Government of Iran constitute an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States” and declaring “a national emergency to deal with the threat.”  In subsequent Executive Orders, the President imposed economic sanctions, including a trade embargo, on Iran.  The Executive Orders and the ITSR prohibit the exportation, re-exportation, sale, or supply, directly or indirectly, to Iran of any goods, technology, or services from the United States or by a United States person without prior authorization or license from the United States Department of the Treasury, the Office of Foreign Assets Control, located in Washington, D.C.

A four-count indictment returned on Oct. 6, 2016, charges Larijani along with Mahan Air, Kral Havacilik IC VE DIS Ticaret Sirketi (Kral Aviation), Toufan Amiri Larijani, Javad Rajabi, Mehdi Bahrami, and Ghodratollah Zarei with conspiracy to export U.S. goods to Iran, specifically U.S. origin commercial aircraft engines, and provide services to a Mahan Air, a SDN, and to defraud the United States; and the U.S. Department of the Treasury and the U.S. Department of Commerce; unlawful exports and attempted exports to embargoed country and provision of services to an SDN; willful violation of denial order; and conspiracy to commit money laundering for purchasing a U.S. origin aircraft engine to supply to Mahan Air in Iran without obtaining an export license.

According to the indictment, beginning around April 2012 through September 2012, Larijani and his co-conspirators attempted to acquire U.S. origin aircraft engines to supply to Mahan Air in Iran without obtaining a license or other authorization from the United States.  Larijani and his co-conspirators caused the shipment of an aircraft engine from the United States with the express purpose of re-exporting the aircraft engine to Iran. 

If convicted, Larijani faces a maximum of 20 years imprisonment.

The investigation was conducted by special agents from the U.S. Department of Commerce, Bureau of Industry and Security Office of Export Enforcement, Miami Field Office/Atlanta Resident Office and Washington Field Office. 

The details contained in an indictment are mere allegations.  All defendants are presumed innocent unless and until proven guilty in a court of law.


DOJ Press Release