You know it's big news when the US Treasury Department issues the press release, not OFAC… Two big pieces of news on the Iran sanctions front. First, Sambouk Shipping FZC has been sanctioned as a front company for Dr. Dimitris Cambis, who was previously sanctioned for trying to evade the […]
Under the Terrorist Asset-Freezing etc. Act of 2010, Her Majesty's Treasury may make either interim or final designations of terrorists, or those who aid and abet them, whose assets are to be frozen. A final designation is good for one year. If HMT does not renew the designation within one […]
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 […]
Two bits of news from England: First, the Burmese asset-freezing sanctions have been lifted by Her Majesty's Treasury, as has the European Union under Council Regulation (EU) No 401/2013. The arms embargo and an embargo on “equipment that might be used for internal oppresion” are not affected. Second, the following […]
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 score for today's SECO updates: Terror – 1 new listing, 13 changed listings Congo – 7 records were changed, and the text brought into line with that of the United Nations Syria – 1 person was removed The Watchlists page has been updated correspondingly. Links: SECO notice – Osama […]
Hot off the presses, just added to the SDN list: FLORES PACHECO, Cenobio (a.k.a. CASTRO VILLA, Luis Fernando; a.k.a. “CHECO”; a.k.a. “CHEKO”); DOB 13 Nov 1974; citizen Mexico (individual) [SDNTK]. LOPEZ AISPURO, Armando; DOB 27 Oct 1969; POB Culiacan, Sinaloa, Mexico; citizen Mexico (individual) [SDNTK]. NIEBLAS NAVA, Guillermo (a.k.a. NIEBLA […]
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), […]
Actually, it only took the Canadians an extra day to remove him from the Consolidated List (compared to DFAT, which completed their action on Thursday) – when you consider the 14+ hour head start that the Aussies have, it's basically the same time frame. Links: OSFI Notice United Nations notice […]
Mr. Watchlist 