Monthly Archives: July 2015

07.31.15
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July 30, 2015: OFAC issues Crimea sanctions evasion advisory

Surprise! People are trying to evade the Crimean sanctions (from Executive Order 13685) from OFAC by omitting or oscuring references to Crimea. OFAC has issued an advisory highlighting the practices it has noticed, including:

In the context of financial transactions, OFAC has become aware that certain individuals or entitieshave engaged in a pattern or practice of repeatedly omitting originator or beneficiary addressinformation from Society for Worldwide Interbank Financial Telecommunications (SWIFT)messages involving individuals ordinarily resident in, or entities located in, Crimea (collectively,”Crimean individuals or entities”). Some SWIFT messages omit all originator or beneficiary addressinformation while other payment messages contain only partial address information for Crimeanindividuals or entities, including, for example, a street address but no reference to a town, city,region, or country. Financial institutions have discovered the data missing from these SWIFTmessages through enhanced due diligence efforts performed on one of the transaction parties afteridentifying a suspicious Crimea-related pattern or practice.

OFAC has also included a section of controls that firms should have in place to stay compliant with the very general Crimean sanctions, including:

  • Ensuring that transaction monitoring systems include appropriate search terms correspondingto major geographic locations in Crimea and not simply references to “Crimea.” Forexample, payment instructions or trade documents may reference major cities or ports locatedin Crimea, and interdiction filters may not flag such transactions for review if the filters donot include an appropriately expansive list of search terms.
  • Requesting additional information from parties (including financial institutions, corporateentities, and individuals) that previously have violated or attempted to violate U.S. sanctionson Crimea. Such prior conduct could include, for example, routing transactions to or throughU.S. financial institutions with inaccurate or incomplete address information for Crimeanindividuals or entities.
  • Clearly communicating U.S. sanctions obligations to international partners (in both thefinancial and trade sectors) and discussing OFAC sanctions compliance expectations withcorrespondent banking and trade partners. Such communications should include, forexample, a description of the prohibition on the direct and indirect exportation orreexportation of goods, technology, and services (including financial services) from theUnited States to Crimea.

Links:

OFAC Notice

Crimea Sanctions Advisory

Executive Order 13685

 

07.31.15
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July 30, 2015: OFAC makes Ukraine/Crimea SDN and SSI additions, Cote d’Ivoire removals

Yesterday, OFAC added the following people to the SDN List under the Ukraine-related sanctions program:

BULYUTIN, Andrey, London, United Kingdom; DOB 19 Oct 1979; POB Izhevsk, Russia; citizen Russia; Passport 515356705 (Russia); Business Development Manager at Kalashnikov Concern (individual) [UKRAINE-EO13661].
KLYUYEV, Andriy Petrovych (a.k.a. KLIUIEV, Andrii Petrovych; a.k.a. KLUEV, Andriy; a.k.a. KLYUEV, Andriy; a.k.a. KLYUYEV, Andrey); DOB 12 Aug 1964; POB Donetsk, Ukraine (individual) [UKRAINE-EO13660].
KOLBIN, Petr (a.k.a. KOLBIN, Peter; a.k.a. KOLBIN, Petr Viktorovich; a.k.a. KOLBIN, Pyotr); DOB 02 Jan 1952; POB Russia (individual) [UKRAINE-EO13661].
KURCHENKO, Sergey Vitalievich (a.k.a. KURCHENKO, Sergei; a.k.a. KURCHENKO, Sergii; a.k.a. KURCHENKO, Serhiy; a.k.a. KURCHENKO, Serhiy Vitaliyovych); DOB 21 Sep 1985 (individual) [UKRAINE-EO13660].
OMELCHENKO, Aleksander (a.k.a. OMELCHENKO, Aleksandr Anatolyevich; a.k.a. OMELCHENKO, Alexander A.; a.k.a. OMELCHENKO, Alexander Anatolyevich; a.k.a. OMELCHENKO, Alexandr Anatolyevich); DOB 08 Sep 1983; POB Moscow, Russia; citizen Russia; Passport 721937258 (Russia); National ID No. 4598338396 (Russia); alt. National ID No. 4506978162 (Russia); Chief Export Officer for Kalashnikov Concern (individual) [UKRAINE-EO13661].
PAANANEN, Kai (a.k.a. PAANANEN, Kai Lauri Johannes); DOB 21 Jul 1954; Chairman, SET Petrochemicals Oy; Managing Director, Southeast Trading Oy (individual) [UKRAINE-EO13661].
ROTENBERG, Roman, Beregovaya, Street 6, Apartment 25, Moscow 125367, Russia; DOB 07 Apr 1981; citizen Russia; alt. citizen Finland; Passport 640848350 (Russia); alt. Passport 16038132 (Finland); alt. Passport 17017258 (Finland) (individual) [UKRAINE-EO13661].
SEMENOVA, Olena Yurevna (a.k.a. SEMENOVA, Elena Iurevna); DOB 06 Dec 1978; citizen Ukraine; Passport ER747251 (Ukraine); National ID No. 2882908207 (Ukraine) (individual) [UKRAINE-EO13661].
STAVYTSKY, Eduard Anatoliyovych (a.k.a. STAVYTSKYI, Eduard; a.k.a. STAVYTSKYY, Eduard); DOB 04 Oct 1972; POB Lebedyn, Ukraine; citizen Ukraine; alt. citizen Israel (individual) [UKRAINE-EO13660].
USACHEV, Oleg (a.k.a. USACHEV, Oleg Leonidovich); DOB 03 Jul 1970 (individual) [UKRAINE-EO13661].
YANUKOVYCH, Oleksandr Viktorovych (a.k.a. YANUKOVICH, Alexander; a.k.a. YANUKOVICH, Oleksander; a.k.a. YANUKOVYCH, Aleksandr Viktorovych; a.k.a. YANUKOVYCH, Olexander); DOB 01 Jul 1973; POB Donetsk, Ukraine (individual) [UKRAINE-EO13660].

Two things to note here. First, there are designations both under Executive Order 13660 (the original one against former Ukrainian officials) and 13661 (against Russian officials). Second, I note that Roman Rotenberg was designated – his relatives transferred some of their assets, including an arena in Finland, to him to avoid sanctions some months ago.

OFAC also added the following entities under the Ukraine-related and Crimea (Executive Order 13685) sanctions:

AIRFIX AVIATION OY, Tullimiehentie 4-6, Vantaa 01530, Finland; Chemin des Papillons 4, Geneva/Cointrin 1216, Switzerland [UKRAINE-EO13661].
IPP OIL PRODUCTS (CYPRUS) LIMITED, 12 Esperidon Street, 4th Floor, Nicosia 1087, Cyprus; Public Registration Number C210706 [UKRAINE-EO13661].
IZHEVSKY MEKHANICHESKY ZAVOD JSC (a.k.a. BAIKAL), 8 Promyshlennaya Str., Izhevsk 426063, Russia; Website http://www.baikalinc.ru [UKRAINE-EO13661].
OPEN JOINT STOCK COMPANY “KONTSERN IZHMASH” (a.k.a. OJSC KONTSERN IZHMASH), 3 Deryabin Proezd, Izhevsk, Udmurt Republic 426006, Russia; Public Registration Number 1021801434380 [UKRAINE-EO13661].
OY LANGVIK CAPITAL LTD, Tanskarlantie 9, Jorvas 02420, Finland; National ID No. 19607726 [UKRAINE-EO13661].
PRIVATE JOINT-STOCK COMPANY MAKO HOLDING (a.k.a. MAKO HOLDING), Bohdan Khmelnytsky Avenue, Building 102, Voroshilovsky District, Donetsk, Donetsk Oblast 83015, Ukraine; Website http://mako.ua/; Email Address a.kyzura@mako-holding.com; Government Gazette Number 34436105 (Ukraine) [UKRAINE-EO13660] (Linked To: YANUKOVYCH, Oleksandr Viktorovych).
SET PETROCHEMICALS OY, Ukonvaaja 2 A, Espoo 02130, Finland [UKRAINE-EO13661].
SOUTHEAST TRADING OY (a.k.a. SOUTHEAST TRADING LTD), Bucharest, Romania; St. Petersburg, Russia; Espoo, Finland; Kannelkatu 8, Lappeenranta 53100, Finland; PL 148, Lappeenranta 53101, Finland [UKRAINE-EO13661].
SOUTHPORT MANAGEMENT SERVICES LIMITED, De Castro Street 24, Akara Building, Wickhams Cay 1, Road Town, Tortola, Virgin Islands, British; Nicosia, Cyprus [UKRAINE-EO13661].
STATE ENTERPRISE EVPATORIA SEA COMMERCIAL PORT (a.k.a. PORT OF EVPATORIA; a.k.a. PORT OF YEVPATORIA; a.k.a. SEAPORT OF YEVPATORIYA; a.k.a. YEVPATORIA COMMERCIAL SEAPORT; a.k.a. YEVPATORIA MERCHANT SEA PORT; a.k.a. YEVPATORIA SEA PORT; a.k.a. YEVPATORIYA COMMERCIAL SEA PORT; a.k.a. YEVPATORIYA SEA PORT), Mariners Square 1, Evpatoria, Crimea 97416, Ukraine; 1, Moryakov Sq, Yevpatoriya, Crimea 97408, Ukraine; 1 Moryakov Sq., Yevpatoria, Crimea 97416, Ukraine; Ukraine; 1 Moryakov Sq, Yevpatoriya, Crimea 97416, Ukraine; Email Address lada1@seavenue.net; alt. Email Address zamves@emtp.com.ua; UN/LOCODE UA ZKA; Registration ID 01125583 (Ukraine) [UKRAINE-EO13685].
STATE ENTERPRISE FEODOSIA SEA TRADING PORT (a.k.a. PORT OF FEODOSIA; a.k.a. SEAPORT OF FEODOSIYA; a.k.a. THEODOSIA COMMERCIAL SEAPORT; a.k.a. THEODOSIA MERCHANT SEA PORT; a.k.a. THEODOSIA SEA PORT), 14 Gorky Street, Theodosia 98100, Ukraine; 14, Gorky Str., Feodosiya, Crimea 98100, Ukraine; Gorky Street 11, Feodosia, Crimea 98100, Ukraine; Website http://www.ukrport.org.ua; Email Address theodosia@port.kafa.crimea.ua; UN/LOCODE UA FEO; Registration ID 01125577 (Russia) [UKRAINE-EO13685].
STATE ENTERPRISE KERCH SEA COMMERCIAL PORT (a.k.a. KERCH COMMERCIAL SEAPORT; a.k.a. KERCH MERCHANT SEA PORT; a.k.a. KERCH SEA PORT; a.k.a. PORT OF KERCH; a.k.a. SEAPORT OF KERCH; a.k.a. STATE ENTERPRISE KERCH COMMERCIAL SEA PORT), Kirova Street 28, Kerch, Crimea 98312, Ukraine; 28 Kirova Str., Kerch, Crimea 98312, Ukraine; 28, Kirov Str., Kerch, Crimea 98312, Ukraine; Ul. Kirov, 28, Kerch, Crimea 98312, Ukraine; ul Kirova 28, Kerch 98312, Ukraine; Website http://www.kerchport.com; alt. Website http://www.ukrport.org.ua; Email Address kmtp@kerch.sf.ukrtel.net; alt. Email Address referent.port@mail.ru; alt. Email Address kmtp@trport.kerch.crimea.com; UN/LOCODE UA KEH; Registration ID 01125554[UKRAINE-EO13685].
STATE ENTERPRISE SEVASTOPOL SEA TRADING PORT (a.k.a. PORT OF SEVASTOPOL; a.k.a. SEAPORT OF SEVASTOPOL; a.k.a. SEVASTOPOL COMMERCIAL SEAPORT; a.k.a. SEVASTOPOL MERCHANT SEA PORT; a.k.a. SEVASTOPOL SEA PORT; a.k.a. SEVASTOPOL SEA TRADE PORT; a.k.a. STATE ENTERPRISE SEVASTOPOL COMMERCIAL SEAPORT), 3 Place Nakhimova, Sevastopol 99011, Ukraine; 5, Nakhimova square, Sevastopol, Crimea 99011, Ukraine; Nahimova Square 5, Sevastopol, Crimea 99011, Ukraine; Email Address Sevport@stel.sebastopol.ua; alt. Email Address sevampu@ukr.net; alt. Email Address mail@morport.sebastopol.ua; UN/LOCODE UA SVP; Registration ID 01125548 (Ukraine) [UKRAINE-EO13685].
STATE ENTERPRISE YALTA SEA TRADING PORT (a.k.a. PORT OF YALTA; a.k.a. SEAPORT OF YALTA; a.k.a. YALTA COMMERCIAL SEAPORT; a.k.a. YALTA MERCHANT SEA PORT; a.k.a. YALTA SEA PORT), Roosevelt Street 3, Yalta, Crimea 98600, Ukraine; 5, Roosevelt Str., Yalta, Crimea 98600, Ukraine; 5 Roosevelt Street, Yalta, Crimea 98600, Ukraine; Website yaltaport.com.ua; Email Address yasko@ukrpost.ua; alt. Email Address yasco@mail.ylt.crimea.com; UN/LOCODE UA YAL; Registration ID 01125591 (Ukraine) [UKRAINE-EO13685].
STATE SHIPPING COMPANY KERCH SEA FERRY (a.k.a. STATE FERRY ENTERPRISE KERCH FERRY), Tselimbernaya Street 16, Kerch, Crimea 98307, Ukraine; 16 Tselibernaya Street, Kerch, Crimea 98307, Ukraine; Registration ID 14333981 (Ukraine) [UKRAINE-EO13685].

The six shipping companies are the first designations since Russian National Commercial Bank was added a while ago.

OFAC also added the following 35 companies to the Sectoral Sanctions Identification (SSI) List:

BANK BELVEB OJSC (a.k.a. BELVESHECONOMBANK OAO; a.k.a. BELVNESHECONOMBANK OPEN JOINT STOCK COMPANY), 29 Pobeditelei ave., Minsk 220004, Belarus; SWIFT/BIC BELB BY 2X; Website bveb.by; Executive Order 13662 Directive Determination – Subject to Directive 1; All offices worldwide; for more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
CJSC VANKORNEFT (a.k.a. VANKORNEFT; a.k.a. ZAO VANKORNEFT), Dobrovolcheskoy Brigady St., 15, Krasnoyarsk Territory 660077, Russia; Email Address info@vankoroil.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
DEVELOPMENT CORPORATION OF NORTH CAUCASUS OJSC (f.k.a. KRSK, OAO; a.k.a. OJSC NORTH CAUCASUS DEVELOPMENT CORPORATION; a.k.a. OPEN JOINT-STOCK COMPANY NORTH CAUCASUS DEVELOPMENT CORPORATION; a.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO KORPORATSIYA RAZVITIYA SEVERNOGO KAVKAZA), d. 139 ul. Pyatigorskaya Essentuki, Stavropolski krai 357625, Russia; Website krskfo.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1102632003253; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
EXIAR (a.k.a. EKSAR OAO; a.k.a. EXIAR OJSC; a.k.a. ROSSISKOE AGENTSTVO PO STRAKHOVANIYU EKSPORTNYKH KREDITOV I INVESTITSI OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. RUSSIAN AGENCY FOR EXPORT CREDIT AND INVESTMENT INSURANCE OJSC), str. 1 3 1-i Zachatievski per, Moscow, 119034, Russia; Website exiar.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1117746811566; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
EXIMBANK OF RUSSIA (a.k.a. GOSUDARSTVENNY SPETSIALIZIROVANNY ROSSISKI EKSPORTNO-IMPORTNY BANK (ZAKRYTOE AKTSIONERNOE OBSHCHESTVO); a.k.a. ROSEKSIMBANK, ZAO; a.k.a. RUSSIAN EXPORT-IMPORT BANK; a.k.a. STATE SPECIALIZED RUSSIAN EXPORT-IMPORT BANK (CLOSED JOINT-STOCK COMPANY)), d.13 str. 1 per.3-I Neopalimovski, Moscow 119121, Russia; SWIFT/BIC EXIR RU MM; Website eximbank.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1027739109133; All offices worldwide; for more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
FAR EAST AND BAIKAL REGION DEVELOPMENT FUND OJSC (a.k.a. FOND RAZVITIYA DALNEGO VOSTOKA I BAIKALSKOGO REGIONA, OAO; a.k.a. OJSC THE FAR EAST AND BAIKAL REGION DEVELOPMENT FUND; a.k.a. OPEN JOINT-STOCK COMPANY THE FAR EAST AND BAIKAL REGION DEVELOPMENT FUND; a.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO FOND RAZVITIYA DALNEGO VOSTOKA I BAIKALSKOGO REGIONA), d. 82 str. 2 ul. Sadovnicheskaya, Moscow 115035, Russia; Website fondvostok.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1112721010995; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
FEDERAL CENTER FOR PROJECT FINANCE (a.k.a. FTSPF, OAO; a.k.a. OAO FEDERALNY TSENTR PROEKTNOGO FINANSIROVANIYA; f.k.a. ZAKRYTOE AKTSIONERNOE OBSHCHESTVO FEDERALNY CENTR PROEKTNOGO FINANSIROVANIYA; a.k.a. “FCPF”), d. 14 prospekt Olimpiski, Moscow 129090, Russia; Website fcpf.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1027739088410; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
GLOBEXBANK (a.k.a. AKTSIONERNOE OBSHCHESTVO KOMMERCHESKI BANK GLOBEKS; f.k.a. CJSC GLOBEXBANK; a.k.a. GLOBEKSBANK, AO; a.k.a. GLOBEX COMMERCIAL BANK, JOINT STOCK COMPANY; f.k.a. ZAKRYTOE AKTSIONERNOE OBSHCHESTVO KOMMERCHESKI BANK GLOBEKS), d. 59 str. 2 ul. Zemlyanoi Val, Moscow 109004, Russia; SWIFT/BIC GLOB RU MM; Website globexbank.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1027739326010; All offices worldwide; for more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
KRASLESINVEST CJSC (a.k.a. CJSC KRASLESINVEST; a.k.a. KRASLESINVEST, ZAO; a.k.a. THE CLOSED JOINT-STOCK COMPANY KRASLESINVEST; a.k.a. ZAKRYTOE AKTSIONERNOE OBSHCHESTVO KRASLESINVEST), d. 35 A ul. Partizana Zheleznyaka, Krasnoyarsk, Krasnoyarski krai 660022, Russia; Website kraslesinvest.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1082468004574; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
NEFT-AKTIV LLC (a.k.a. OOO NEFT-AKTIV; a.k.a. RN-AKTIV OOO), Ulica Kaluzhskaya M., d., 15, str. 28, Moscow 119071, Russia; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC ACHINSK REFINERY (a.k.a. ACHINSK REFINERY; a.k.a. OAO ACHINSK OIL REFINERY VNK), Achinsk Refinery industrial area, Bolsheuluisky district, Krasnoyarsk territory 662110, Russia; Email Address sekr1@anpz.rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC ANGARSK PETROCHEMICAL COMPANY (a.k.a. ANGARSK REFINERY), Angarsk, Irkutsk region 665830, Russia; 6 ul. K. Marksa, Angarsk 665830, Russia; Website http://www.anhk.ru; Email Address delo@anhk.rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC KUYBYSHEV REFINERY (a.k.a. KUIBYSHEV REFINERY; a.k.a. OJSC KUIBYSHEV REFINERY), 25 Groznenskaya st., Samara 443004, Russia; Email Address sekr@knpz.rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC NOVOKUYBYSHEV REFINERY (a.k.a. NOVOKUIBYSHEVSK REFINERY; a.k.a. OJSC NOVOKUYBYSHEV REFINERY), Novokuibyshevsk, Samara region 446207, Russia; Email Address sekr@nknpz.rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC ORENBURGNEFT (a.k.a. OAO JSC ORENBURGNEFT; a.k.a. ORENBURGNEFT), Magistralnaya St., 2, Buzuluk, the Orenburg Region 461040, Russia; st. Magistralynaya 2, Buzuluk 461040, Russia; Email Address orenburgneft@rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC RN HOLDING (a.k.a. RN HOLDING OAO), 60 Oktyabrskaya ul., Uvat 626170, Russia; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; Registration ID 1047200153770 (Russia); Tax ID No. 7225004092 (Russia); Government Gazette Number 74743120 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC RUSSIAN REGIONAL DEVELOPMENT BANK (a.k.a. RUSSIAN REGIONAL DEVELOPMENT BANK; a.k.a. “VBRR”), 65/1 Suschevsky Val, Moscow 129594, Russia; 65 Sushchevskiy val, Moscow 129594, Russia; Website http://www.vbrr.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; Registration ID 3287 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC SAMOTLORNEFTEGAZ (a.k.a. SAMOTLORNEFTEGAZ; a.k.a. SAMOTLORNEFTEGAZ JSC), Lenina St. 4, the Tyumen Region, Khanty-Mansiysk, Autonomous District, Nizhnevartovsk 628606, Russia; Email Address NVSNGinfo@rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC SYZRAN REFINERY (a.k.a. OPEN JOINT-STOCK OIL AND GAS COMPANY SYZRAN; a.k.a. SYZRAN REFINERY), 1 Astrakhanskaya st., Syzran, Samara region 446009, Russia; Moskvorechje street 105, Building 8, Moscow 115523, Russia; Email Address sekr@snpz.rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
PJSC VERKHNECHONSKNEFTEGAZ (a.k.a. OJSC VERKHNECHONSKNEFTEGAZ; a.k.a. VERKHNECHONSKNEFTEGAZ), Baikalskaya St., 295 B, Irkutsk 664050, Russia; Email Address vcng@rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
PROMINVESTBANK (a.k.a. COMMERCIAL INDUSTRIAL AND INVESTMENT BANK PUBLIC JOINT STOCK COMPANY; a.k.a. JOINT STOCK COMMERCIAL INDUSTRIAL AND INVESTMENT BANK PUBLIC JOINT STOCK COMPANY; a.k.a. PSC PROMINVESTBANK; a.k.a. PUBLIC STOCK COMPANY JOINT STOCK COMMERCIAL INDUSTRIAL & INVESTMENT BANK), 12, Shevchenko lane, Kyiv 01001, Ukraine; SWIFT/BIC UPIB UA UX; Website pib.com.ua; Executive Order 13662 Directive Determination – Subject to Directive 1; All offices worldwide; for more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
RESAD LLC (a.k.a. LLC RESAD; a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU RESAD; a.k.a. RESAD, OOO), d. 5 ul. Bryanskaya, Moscow 121059, Russia; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1027739071337; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
RN-KOMSOMOLSKY REFINERY LLC (a.k.a. KOMSOMOLSK REFINERY; a.k.a. LLC RN-KOMSOMOLSK REFINERY; a.k.a. RN-KOMSOMOLSKI NPZ OOO), 115 Leningradskaya st., Komsomolsk-on-Amur, Khabarovsk region 681007, Russia; Email Address knpz@rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
RN-YUGANSKNEFTEGAZ LLC (a.k.a. RN-YUGANSKNEFTEGAZ OOO; a.k.a. YUGANSKNEFTEGAZ), Lenina St., 26, Nefteyugansk, Tyumen Region 628309, Russia; Email Address rn_yng@yungjsc.com; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
ROSE GROUP LIMITED (f.k.a. RGI INTERNATIONAL; f.k.a. RGI INTERNATIONAL LIMITED; a.k.a. “ROSE GROUP”), Frances House, Sir William Place, St. Peter Port GY1 4EU, Guernsey; Korobeinikov Lane, 1, Moscow 119034, Russia; Website rosegroup.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
ROSNEFT FINANCE S.A., 46A Avenue John F Kennedy, 2nd Floor, Luxembourg 1855, Luxembourg; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
ROSNEFT TRADE LIMITED (f.k.a. TNK TRADE LIMITED), Elenion Building 5 Themistokli Dervi, 2nd floor, Lefkosia, Nicosia 1066, Cyprus; Email Address hrm@rosneft-sh.com.cy; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; Registration ID C122790; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
ROSNEFT TRADING S.A., 2, Rue Place du Lac, 1204, Geneva, Switzerland; Website http://www.rosneft.com; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
RUSSIAN DIRECT INVESTMENT FUND MANAGEMENT COMPANY (a.k.a. LIMITED LIABILITY COMPANY RDIF MANAGEMENT COMPANY; a.k.a. MANAGEMENT COMPANY RDIF LLC; a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU UPRAVLYAYUSHCHAYA KOMPANIYA RFPI; a.k.a. RDIF MANAGEMENT COMPANY; a.k.a. RDIF MANAGEMENT COMPANY LLC; a.k.a. UK RFPI, OOO), d. 9 prospekt Akademika Sakharova, Moscow 107996, Russia; Website rdif.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1117746429371; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
SME BANK (a.k.a. AKTSIONERNOE OBSHCHESTVO ROSSISKI BANK PODDERZHKI MALOGO I SREDNEGO PREDPRINIMATELSTVA; a.k.a. JSC RUSSIAN BANK FOR SMALL AND MEDIUM ENTERPRISES SUPPORT; a.k.a. JSC SME BANK; a.k.a. MSP BANK AO; f.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO ROSSISKI BANK RAZVITIYA), 79 ul. Sadovnicheskaya, Moscow 115035, Russia; SWIFT/BIC RUDV RU MM; Website mspbank.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1027739108649; All offices worldwide; for more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
SVIAZ-BANK (a.k.a. INTERREGIONAL BANK FOR SETTLEMENTS OF THE TELECOMMUNICATIONS AND POSTAL SERVICES; a.k.a. MEZHREGIONALNY KOMMERCHESKI BANK RAZVITIYA SVYAZI I INFORMATIKI (PUBLICHNOE AKTSIONERNOE OBSHCHESTVO); a.k.a. SVIAZ-BANK AKB PAO), 7 Tverskaya ul., Moscow 125375, Russia; SWIFT/BIC SVIZ RU MM; Website sviaz-bank.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1027700159288; All offices worldwide; for more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
VEB ASIA LIMITED, Suite 5808, 58/F, Two International Finance Center, 8 Finance Street Central, Hong Kong, China; Executive Order 13662 Directive Determination – Subject to Directive 1; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
VEB CAPITAL (a.k.a. LIMITED LIABILITY COMPANY VEB CAPITAL; a.k.a. LLC VEB-CAPITAL; a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU INVESTITSIONNAYA KOMPANIYA VNESHEKONOMBANKA (VEB KAPITAL); a.k.a. VEB CAPITAL LLC; a.k.a. VEB KAPITAL, OOO), d. 7 str. A ul. Mashi Poryvaevoi, Moscow 107078, Russia; Website vebcapital.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1097746831709; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
VEB ENGINEERING LLC (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU VEB INZHINIRING; a.k.a. VEB INZHINIRING, OOO), d. 9 prospekt Akademika Sakharova, Moscow 107996, Russia; Website vebeng.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1107746181674; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
VEB LEASING OJSC (a.k.a. OJSC VEB-LEASING; a.k.a. OPEN JOINT-STOCK COMPANY VEB-LEASING; a.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO VEB-LIZING; a.k.a. VEB-LIZING, OAO), d. 10 ul. Vozdvizhenka, Moscow 125009, Russia; Website veb-leasing.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1037709024781; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).

and removed the following 5 people from the SDN List's Cote d'Ivoire sanctions program:

DJEDJE, Alcide Ilahiri (a.k.a. DJEDJE, Ilahiri Alcide; a.k.a. ILAHIRI, Alcide Djedje); DOB 1956 (individual) [COTED].
DJEDJE, Ilahiri Alcide (a.k.a. DJEDJE, Alcide Ilahiri; a.k.a. ILAHIRI, Alcide Djedje); DOB 1956 (individual) [COTED].
ILAHIRI, Alcide Djedje (a.k.a. DJEDJE, Alcide Ilahiri; a.k.a. DJEDJE, Ilahiri Alcide); DOB 1956 (individual) [COTED].
N'GUESSAN, Pascal Affi (a.k.a. NGUESSAN, Affi); DOB 1953; POB Bongouanou, Cote d Ivoire (individual) [COTED].
NGUESSAN, Affi (a.k.a. N'GUESSAN, Pascal Affi); DOB 1953; POB Bongouanou, Cote d Ivoire (individual) [COTED].

There was also an advisory issued about Crimean sanctions, but I'll cover that separately.

Links:

OFAC Notice

 

07.31.15
by

HKMA fines State Bank of India 7.5MM HKD for AML failures

Notable not only for actually enforcing its AML statutes, but for publicizing it, today the Hong Kong Monetary Authority (HKMA) fined State Bank of India's (SBI) Hong Kong operation for the following AML program deficiencies:

SBIHK failed to:-

(a) carry out the customer due diligence measures set out in sections 2(1)(a) and 2(1)(b) of Schedule 2 to the AMLO before establishing business relationships with 28 corporate customers;

(b) continuously monitor its business relationships with its customers;

(c) establish and maintain effective procedures for determining whether its customers or beneficial owners of its customers were politically exposed persons; and

(d) establish effective procedures to ensure compliance with the specified provisions in sections 3 and 5 of Schedule 2 to the AMLO.

In addition, the firm must submit a report on the sufficiency of its remediation plan and the success of its remediation from an independent adviser.

HKMA also noted the mitigating factors in the case:

(a) SBIHK has taken very positive and intensive remediation work to address the contraventions identified in the HKMA’s investigation and other weaknesses identified in the HKMA’s onsite examination;

(b) SBIHK has confirmed through an external consultant that neither actual problem accounts nor suspicious transactions have been identified; and

(c) SBIHK has no previous disciplinary record and co-operated with the HKMA during the investigation.

Very OFAC-like, if I do say so myself. I always thought there was value in the transparency of the OFAC Enforcement Guidelines…

Link:

HKMA Enforcement Action

 

07.30.15
by

FinCEN Enforcement Action: $4.5 million fine for Bank of Mingo for BSA violations

No better way to explain this other than by showing you the news release…

FOR IMMEDIATE RELEASE CONTACT: Steve HudakJune 15, 2015 703-905-3770

FinCEN Penalizes West Virginia Bank for Serious BSA Violations andActions by a Branch Manager That Assisted Criminal Activity

WASHINGTON, D.C. – The Financial Crimes Enforcement Network (FinCEN) todayannounced the assessment of a $4.5 million civil money penalty against Bank of Mingo ofWilliamson, West Virginia (Mingo), for willfully violating the Bank Secrecy Act (BSA). Mingohad severe and systemic failures in many aspects of its anti-money laundering (AML) program.As a result of these failures, Mingo processed millions of dollars in structured and suspiciouscash transactions through the institution.

Mingo serviced high-risk customers without effectively monitoring their accounts for suspiciousactivity. In one example, Mingo was aware of a high volume of unusual cash transactionsconducted by a corporate customer, yet failed to file the requisite currency transaction reports(CTRs) or suspicious activity reports (SARs). That customer conducted over $9 million worth ofstructured transactions through Mingo’s Williamson Branch. The manager of that branch, whois also the former Mayor of Williamson, was convicted in April 2014 of knowingly making afalse statement to federal law enforcement agents during an investigation of that scheme to evadeBSA reporting requirements.

“This bank’s failure to implement and maintain an effective AML program exposed our financialsystem to significant abuse,” said FinCEN Director Jennifer Shasky Calvery. “And, when abank insider actively promotes a culture of noncompliance, the risks are greatly increased.”

From 2008 through 2013, Mingo had significant deficiencies in all aspects of its AML program,including its internal controls, independent testing, training of personnel, and designation of aBSA officer with sufficient resources to adequately oversee its BSA compliance program.Mingo failed to properly assess the money laundering risk associated with its customers.Consequently, Mingo failed to properly designate many customers and their accounts as highrisk; and failed to adequately monitor and detect the unusual currency transactions or suspiciousactivities in which these customers engaged.

FinCEN coordinated its enforcement action with actions by the Federal Deposit InsuranceCorporation (FDIC) and the U.S. Attorney’s Office for the Southern District of West Virginia.The total penalty of $4.5 million will run concurrent with a $3.5 million penalty by the FDIC, ofwhich $2.2 million is concurrent with the amount forfeited pursuant to the deferred prosecutionagreement with the U.S. Attorney’s Office. Accordingly, this penalty will be deemed satisfiedby an immediate payment of $1 million to the U.S. Department of the Treasury; with theremaining balance satisfied by payment of the FDIC civil money penalty and the U.S. Attorney’sforfeiture. Director Shasky Calvery expressed her appreciation to the FDIC and the U.S. Attorney’sOffice for the Southern District of West Virginia for its contributions to the investigation in thisaction and strong partnership with FinCEN. page1image17408

 

Links:

FinCEN News Release

FinCEN Enforcement Action

 

 

07.29.15
by

June 12, 2015: Risk Assessment Alphabet Soup from FinCEN

Treasury Department Publishes National Money Laundering Risk Assessment and National Terrorist Financing Risk Assessment


6/12/2015

​
Reports Identify Key Illicit Finance Concerns to the United States; Enable the Public and Private Sectors to More Effectively Manage and Combat Illicit Finance Risks
WASHINGTON – The U.S. Department of the Treasury today issued the National Money Laundering Risk Assessment (NMLRA) and the National Terrorist Financing Risk Assessment (NTFRA). The purpose of these assessments is to help the public and private sectors understand the money laundering and terrorist financing methods used in the United States, the risks that these activities pose to the U.S. financial system and national security, and the status of current efforts to combat these methods. In doing so, these assessments enable the U.S. Government and financial institutions to more effectively detect and combat illicit finance.
This is the first NTFRA, and the NMLRA builds and expands on a previous Treasury money laundering report issued in 2005. The methodology for today’s reports is based on guidance set out in 2013 by the Financial Action Task Force (FATF), the international standard-setting body for anti-money laundering and counter-terrorist financing safeguards, of which the United States is a founding member. The FATF requires all national governments to demonstrate their understanding of the money laundering and terrorist financing risks facing their financial systems. The assessments issued today will help to inform the FATF’s ongoing review of the United States regarding our compliance with the FATF Recommendations – which are global standards focused on these issues.
The United States is the world’s largest financial system and U.S. financial institutions play a central role in the global economy, processing trillions of dollars of transactions from around the world every day. While this position exposes the United States to increased risks for illicit finance, the U.S. Government has developed a robust regulatory framework, complemented by law enforcement and supervision efforts, which make it more difficult and costly for criminals and terrorists to access and use the U.S. financial system.
“Today’s assessments underscore our dedication to better understand and address the risk of illicit finance,” said Adam J. Szubin, Acting Under Secretary for Terrorism and Financial Intelligence. “This comprehensive review will better inform the U.S. Government and our private sector partners about how to further safeguard and strengthen the U.S. economy and national security.”
The NMLRA finds that the United States has effectively kept pace with innovation, such that, criminals pursuing money laundering opportunities rely on costly and burdensome methods to mask their identities from financial institutions in order to open and maintain accounts. These include, but are not limited to, using cash, other monetary instruments, shell companies, and conducting transactions below customer identification thresholds. The report also finds that the U.S. framework for anti-money laundering and counter terrorist financing effectively narrows many of the most significant vulnerabilities that money launderers seek to exploit through a core set of tools, including targeted financial sanctions, law enforcement investigations and prosecutions and regulatory preventive measures, and by working to enhance international standards.
The NTFRA finds that the U.S. Government has made it substantially more difficult for terrorist organizations to raise and move money through the U.S. financial system since the September 11, 2001 attacks. A notable trend highlighted in the report is a decrease in the use of the U.S banking system for terrorist financing-related transactions, as terrorists are forced into more expensive and less efficient methods to facilitate terrorist financing, such as cash smuggling. Such channels outside of the regulated financial system are riskier than straightforward bank transfers, making them more vulnerable to disruption and exposure. Nonetheless, the wealth and resources of the United States will continue to make it an attractive target for a wide range of terrorist organizations seeking to fund their activities, and the risk of terrorist financing through the U.S. financial system persists.
The review for these assessments was led by the Treasury Department’s Office of Terrorist Financing and Financial Crimes, and developed in close coordination with offices and bureaus in the Treasury Department, the Department of Justice, the Department of Homeland Security, the Department of State, and across the intelligence community and staffs of the Federal functional regulators.

Links:

FinCEN Notice

2015 National Money Laundering Risk Assessment (NMLRA)

2015 National Terrorist Financing Risk Assessment (NTFRA)

 

07.28.15
by

July 3, 2015: Finnish regulatory update

Finnish regulators regularly recap EU sanctions decisions and regulations that come into force. On July 3rd, they listed the following:

  • Financial sanctions

  • Export and import restrictions

    • Iran
      • Council Decision (CFSP) 2015/1050 continued the temporary suspensions and licensing conditions under the Joint Plan of Action until July 7th. The ban on imports of Iranian petrochemical products, as well as a ban on the transport of Iranian crude oil continues to be suspended. The suspension of the crude oil ban only applies to carriage outside the EU. The import of crude oil and petroleum products in the EU is still not allowed. The ban on trade in gold or precious metals is also suspended.
    • Ukraine, Crimea and Sevastopol

      • Ukraine: Council Decision (CFSP) 2015/971 extends restrictions until 01.31.2016. Defence equipment exports and imports to Russia is prohibited. In addition, it is prohibited to export dual-use items and technology to Russia, or for Russian use, if they are or may be in whole or in part, for military purposes or for military end-users. Dual-use export is prohibited also for separately listed companies that produce products for both civilian and military use. Export restrictions also relates to exploration of oil and certain products related to oil production.
      • Crimea and Sevastopol: Council Decision (CFSP) 2015/959 extends restrictive measures until June 23, 2016. The export of certain goods and technology to the Crimea or Sevastopol is prohibited. Subject to an export ban are the products suitable for use in transport, telecommunications and energy as well as oil, gas and related to the exploitation of mineral resources in key sectors. Also, technical assistance, brokering services and the provision of financing are prohibited related to the above functions. The restrictive measures also prohibit the provision of services directly related to the tourism sector in the Crimea and Sevastopol.

       

  • Travel Restrictions

 

07.27.15
by

July 23, 2015: OFAC designates Singaporean shipping, Mongolian cargo vessel to DPRK sanctions

Last Thursday, OFAC added the following person:

LAI, Leonard (a.k.a. LAI, Yong Chian); DOB 16 Jun 1958; Passport E3251534E (Singapore) expires 20 Mar 2018 (individual) [DPRK

and company:

SENAT SHIPPING LIMITED (a.k.a. SENAT SHIPPING & TRADING PTE LTD; a.k.a. SENAT SHIPPING AGENCY LTD; a.k.a. SENAT SHIPPING AND TRADING LTD; a.k.a. SENAT SHIPPING AND TRADING PRIVATE LIMITED), 36-02 A, Suntec Tower, 9, Temasek Boulevard, Singapore 038989, Singapore; 9 Temasek Boulevard, 36-02A, Singapore 038989, Singapore; Panama City, Panama; PO Box 957, Offshore Incorporations Centre Road Town, Tortola, Virgin Islands, British; Identification Number IMO 5179245; alt. Identification Number IMO 5405737 [DPRK].

and cargo vessel:

DAWNLIGHT General Cargo Mongolia flag; Vessel Registration Identification IMO 9110236 (vessel) [DPRK].

 

to the sanctions against North Korea. In addition, they changed these records:

KIM, TONG-MYO'NG (a.k.a. KIM, CHIN-SO'K; a.k.a. KIM, TONG MYONG; a.k.a. “KIM, JIN SOK”), c/o Tanchon Commercial Bank, Saemul 1-Dong Pyongchon District, Pyongyang, Korea, North; DOB 1964; nationality Korea, North (individual) [NPWMD]. -to- |KIM, Tong-Myo'ng| (|a.k.a. KIM, CHIN-SO'K; a.k.a. KIM, HYOK CHOL; a.k.a. KIM, TONG MYONG; a.k.a. “KIM, JIN SOK”|)|; DOB 1964; alt. DOB 28 Aug 1962; nationality Korea, North; Passport 290320764| (individual) [NPWMD] (|Linked To: TANCHON COMMERCIAL BANK|).
OCEAN MARITIME MANAGEMENT COMPANY LIMITED (a.k.a. EAST SEA SHIPPING COMPANY), Dongheung-dong Changgwang Street, Chung-ku, PO Box 125, Pyongyang, Korea, North; Donghung Dong, Central District, PO Box 120, Pyongyang, Korea, North; No. 10, 10th Floor, Unit 1, Wu Wu Lu 32-1, Zhong Shan Qu, Dalian City, Liaoning Province, China; 22 Jin Cheng Jie, Zhong Shan Qu, Dalian City, Liaoning Province, China; 43-39 Lugovaya, Vladivostok, Russia; CPO Box 120, Tonghung-dong, Chung-gu, Pyongyang, Korea, North; Bangkok, Thailand; Lima, Peru; Port Said, Egypt; Singapore; Brazil; Identification Number IMO 1790183 [DPRK]. -to- OCEAN MARITIME MANAGEMENT COMPANY LIMITED (|a.k.a. EAST SEA SHIPPING COMPANY; a.k.a. HAEYANG CREW MANAGEMENT COMPANY; a.k.a. KOREA MIRAE SHIPPING CO. LTD.|)|, Dongheung-dong Changgwang Street, Chung-ku, PO Box 125, Pyongyang, Korea, North; Donghung Dong, Central District, PO Box 120, Pyongyang, Korea, North; No. 10, 10th Floor, Unit 1, Wu Wu Lu 32-1, Zhong Shan Qu, Dalian City, Liaoning Province, China; 22 Jin Cheng Jie, Zhong Shan Qu, Dalian City, Liaoning Province, China; 43-39 Lugovaya, Vladivostok, Russia; CPO Box 120, Tonghung-dong, Chung-gu, Pyongyang, Korea, North; Bangkok, Thailand; Lima, Peru; Port Said, Egypt; Singapore; Brazil; Hong Kong, China; Shenzhen, China; Identification Number IMO 1790183| [DPRK].
RA, Kyong-Su, Beijing, China; Tanchon Commercial Bank Representative to Beijing, China (individual) [NPWMD]. -to- RA, Kyong-Su (|a.k.a. CHANG, MYONG HO; a.k.a. CHANG, MYO'NG-HO; a.k.a. CHANG, MYONG-HO|), Beijing, China; Tanchon Commercial Bank Representative to Beijing, China (individual) [NPWMD] (|Linked To: TANCHON COMMERCIAL BANK|).

which were designated under the non-proliferation or DPRK programs.

Links:

OFAC Notice