Monthly Archives: November 2014

11.28.14
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Yet another variety of Standard Chartered phish in Hong Kong

Press Releases
Fraudulent website: http://www.standardcharteredv.com/hk

The Hong Kong Monetary Authority (HKMA) wishes to alert members of the public to a fraudulent website with the domain name “http://www.standardcharteredv.com/hk”. The website purports to be the official website of Standard Chartered Bank (Hong Kong) Limited (SCBHK). SCBHK has clarified that it has no connection with the fraudulent website.

Anyone who has provided his or her personal information to the website or has conducted any financial transactions through the website should contact SCBHK at 2886 8868 and any local Police Station or the Commercial Crime Bureau of the Hong Kong Police Force at 2860 5012.

Link:

HKMA Notice

 

11.26.14
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UN Narrative Summary for Ali Abdullah Saleh

The United Nations 2140 committee, when it designates a terrorist for asset freezes and travel bans, includes a narrative of why that person or entity is being designated. This person was designated on November 7:

Ali Abdullah Saleh has engaged in acts that threaten the peace, security, or stability of Yemen, such as acts that obstruct the implementation of the agreement of 23 November 2011 between the Government of Yemen and those in opposition to it, which provides for a peaceful transition of power in Yemen, and acts that obstruct the political process in Yemen.

Per the 23 November 2011 agreement backed by the Gulf Cooperation Council, Ali Abdullah Saleh stepped down as President of Yemen after more than 30 years.

As of fall 2012, Ali Abdullah Saleh had reportedly become one of the primary supporters of violent Huthi actions in northern Yemen.

More recently, as of September 2014, Saleh has been destabilizing Yemen by using others to undermine the central government and create enough instability to threaten a coup. According to a September 2014 report by the United Nations Panel of Experts for Yemen, interlocutors alleged that Saleh supports violent actions of some Yemenis by providing them funds and political support, as well as ensuring that GPC members continue to contribute to the destabilization of Yemen through various means.

The September 2014 United Nations Panel of Experts report on Yemen also states that allegations have been made that Ali Abdullah Saleh has been using Al-Qaida in the Arabian Peninsula (AQAP) operatives to conduct assassinations and attacks against military installations in order to weaken President Hadi and create discontent within the army and broader Yemeni population. Clashes in the south of Yemen in February 2013 were a result of the combined efforts of Saleh, AQAP, and southern secessionist Ali Salim al-Bayd to cause trouble before the 18 March 2013 National Dialogue Conference in Yemen.

 

11.26.14
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Iranian Sanctions Relief extended

Originally, sanctions relief under the Joint Plan of Action (JPOA) was supposed to expire on Monday, November 24, but has now been extended to June 30, 2015. Here are the press releases from the EU (which calls the negotiating group the E3+3, based on 3 EU participants) and OFAC (which calls it P5+1, based on 5 permanent members of the UN Security Council).

Links:

EU Press Release

OFAC Notice

 

11.25.14
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OFAC Enforcement Action: ESCO pays $2,057,540 to OFAC for Cuban Sanctions Violations

ESCO Corporation, an Oregon company, settled allegations that it violated Cuban sanctions regulations between November 2007 and June 2011 when its subsidiary purchased products with nickel of Cuban origin.

The total amount of the transactions was $6,188,149 and the base penalty for the voluntarily self-disclosed, non-egregious violations was $3,048,208.

And here's why the penalty was reduced by less than 1/3 – according to the OFAC enforcement information:

OFAC considered the following to be aggravating factors:

  • ESCO actedwith reckless disregard for Cuba sanctions program by failing to identify, despite the presence ofcontemporaneous “red flags” in the public domain, that the nickel briquettes were made orderived from Cuban-origin nickel;
  • ESCO caused significant harm to the Cuba sanctions programand its policy objectives by conducting large-volume and high-value transactions in productsmade or derived from Cuban-origin nickel, which were ultimately sourced from SpeciallyDesignated Nationals; and
  • ESCO is a commercially sophisticated company with internationaloperations.

OFAC considered the following to be mitigating factors:

  • ESCO has not received apenalty notice or Finding of Violation from OFAC in the five years preceding the date of the firsttransaction giving rise to the apparent violations;
  • ESCO has enhanced its OFAC compliance planand conducted a thorough look-back; and
  • ESCO cooperated with OFAC’s investigation,including by executing and extending a statute of limitations tolling agreement.

So, even though the violations were non-agregious, they did “significant harm” to Cuban sanctions enforcement, and the firm's commercial sophistication means they should have spotted the red flags. Thus, not much of a discount beyond the 25% “first timer” one.

Link:

OFAC Enforcement Info

 

 

11.24.14
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November 18, 2014: Australia telegraphs its upcoming punch

On Tuesday, the Department of Foreign Affairs and Trade (DFAT) submitted the following proposed changes to the sanctions against Russia for comment:

Restrictions on the supply, sale or transfer of goods

The amending regulation would prohibit the unauthorised supply, sale or transfer of the following ‘export sanctioned goods’ for Russia, Crimea and Sevastopol:

Russia
      • arms or related materiel
      • Australian Obligated Nuclear Material
      • equipment and technology for use in deep water oil exploration or production in Russia, Arctic oil exploration or production in Russia, or a shale oil project in Russia, as specified in the Autonomous Sanctions (Russia, Crimea and Sevastopol) Specification 2014;
Crimea and Sevastopol
      • equipment and technology relating to the creation, acquisition or development of infrastructure in the transport, telecommunications and energy sectors and the exploitation of oil, gas and mineral reserves in Crimea and Sevastopol, as specified in the Autonomous Sanctions (Russia, Crimea and Sevastopol) Specification 2014;
Restrictions on the import, purchase or transport of goods

The amending regulation would prohibit the unauthorised import, purchase or transport of the following ‘import sanctioned goods’ for Russia, Crimea and Sevastopol:

Russia
Crimea and Sevastopol
      • all goods exported from Crimea and Sevastopol
Restrictions on the export or provision of services

The amending regulation would prohibit the unauthorised provision of the following ‘sanctioned services’ for Russia, Crimea and Sevastopol:

Russia

the provision to Russia, or a person for use in Russia, of technical advice, assistance or training, or financial assistance, or financial service, or another service, if it assists with, or is provided in relation to:

      • a military activity
      • the manufacture, maintenance or use of arms or related materiel or Australian Obligated Nuclear Material
      • engagement in a sanctioned commercial activity for Russia

the provision to Russia, or to a person, entity or body for use in Russia, the following services necessary for deep water oil exploration or production in Russia, Arctic oil exploration or production in Russia, or a shale oil project in Russia:

      • drilling
      • well-testing
      • logging and completion services
      • supply of specialised floating vessels
Crimea and Sevastopol

the provision to Crimea or Sevastopol, or a person for use in Crimea or Sevastopol, of technical advice, assistance or training, or financial assistance, or financial service, or another service, if it assists with, or is provided in relation to:

      • the manufacture, maintenance or use of an ‘export sanctioned good’ for Crimea or Sevastopol
      • engagement in a ‘sanctioned commercial activity’ for Crimea or Sevastopol
Restrictions on commercial activities

The amending regulation would prohibit the unauthorised engagement in the following ‘sanctioned commercial activities’ for Russia, Crimea and Sevastopol:

Russia
      • the direct or indirect purchase or sale of, or any other dealing with, bonds, equity, transferable securities, money market instruments or other similar financial instruments, if the financial instrument is issued by Russian state-owned banks, entities involved in military supplies and services and entities selling or transporting crude oil and petroleum products, specified in the Autonomous Sanctions (Russia, Crimea and Sevastopol) Specification 2014 and has a maturity period exceeding thirty days, as specified in the Autonomous Sanctions (Russia, Crimea and Sevastopol) Specification 2014;
Crimea and Sevastopol
      • the granting of any financial loan or credit, or the establishment of a joint venture, relating to the creation, acquisition or development of infrastructure in the transport, telecommunications or energy sectors and the exploitation of oil or gas, or of mineral reserves, in Crimea and Sevastopol, as specified in the Autonomous Sanctions (Russia, Crimea and Sevastopol) Specification 2014;
      • the acquisition or extension of an interest in an enterprise established in Crimea or Sevastopol and is engaged in the creation, acquisition or development of infrastructure in the transport, telecommunications or energy sectors and the exploitation of oil or gas, or of specified mineral reserves, in Crimea and Sevastopol.

The comment period ends on December 9th.

Link:

DFAT Public Consultation page

 

11.24.14
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November 21, 2014: HMT renews Bilal Talal Abdul Samad Abdullah under TAFA

On Friday, Her Majesty’s Treasury (HMT) renewed the Final Designation of the following person:

1. ABDULLAH, Bilal, Talal, Abdul, Samad
DOB: (1) 24/08/1979.

(2) 27/08/1979.
a.k.a: ABDULLA, Bilal

Nationality: British


Passport Details: 702172116 (British). Issued 19 Aug 1998

Address:

(1) Paisley, United Kingdom (previous address), PA2.


(2) Houston, United Kingdom (previous address), PA6.
(3) Greenock, United Kingdom (previous address), PA16.
(4) Cambridge, United Kingdom (previous address), CB4.
(5) Cambridge, United Kingdom (previous address), CB2.
(6) Cambridge, United Kingdom (previous address), CB1.

Other Information: UK listing only. Male. Sentenced to two terms of life
imprisonment in Dec 2008. In custody in the UK (as at Nov 2014).
Group ID: 9149.

for an additional year under the Terrorist Asset-Freezing etc. Act 2010 (TAFA). You’ll notice the “UK listing only” under Other Information – some of the TAFA listings emanate from the EU.

Link:

HMT Notice

 

11.21.14
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November 19, 2014: OFAC adds to Kingpin Act sanctions list

On Wednesday, the Office of Foreign Assets Control (OFAC) added the following persons:

ARREDONDO ORTIZ, Carlos Arturo (a.k.a. “MATEO”); DOB 22 Nov 1966; POB Itagui, Antioquia, Colombia; citizen Colombia; Cedula No. 98520515 (Colombia) (individual) [SDNTK].
BEDOYA LOPEZ, Gildardo de Jesus; DOB 18 Dec 1963; POB Abejorral, Antioquia, Colombia; citizen Colombia; Cedula No. 70560012 (Colombia) (individual) [SDNTK] (Linked To: COLOMBIANA DE BIOCOMBUSTIBLES S.A.; Linked To: REPRESENTACIONES MIDAS; Linked To: GARCES Y BEDOYA CIA. LTDA).
ECHEVERRI PAREJA, Oscar Alonso (a.k.a. “MOSCO”); DOB 07 May 1971; POB Envigado, Antioquia, Colombia; citizen Colombia; Cedula No. 98564040 (Colombia) (individual) [SDNTK] (Linked To: ACUAMATERIALES Y CIA. LIMITADA).
GALLEGO ORREGO, Margarita Zulay; DOB 18 Oct 1953; POB Yolombo, Antioquia, Colombia; citizen Colombia; Cedula No. 32334460 (Colombia) (individual) [SDNTK] (Linked To: ENVIGADO FUTBOL CLUB S.A.; Linked To: ENFARRADOS COMPANY S.A.S.; Linked To: CENTRO DE DIAGNOSTICO AUTOMOTOR DEL SUR LTDA.; Linked To: CAFETERIA ENVICENTRO; Linked To: TIENDAS MARGOS).
GARCIA ARBOLEDA, Edward (a.k.a. “ORION”); DOB 04 Jun 1975; POB Urrao, Antioquia, Colombia; citizen Colombia; Cedula No. 98624193 (Colombia) (individual) [SDNTK] (Linked To: LA TIENDA DE MINGO; Linked To: INVERSIONES C.P.C.L. Y CIA. S. EN C.S.).
GUTIERREZ RESTREPO, Luis Fernando (a.k.a. “LUIFER”); DOB 13 Aug 1958; POB Belmira, Antioquia, Colombia; citizen Colombia; Cedula No. 70550107 (Colombia) (individual) [SDNTK] (Linked To: ROBIREPUESTOS; Linked To: IMPORTADORA MARENOL LIMITADA).
ISAZA SANCHEZ, Felix Alberto (a.k.a. “BETO”); DOB 24 Apr 1966; POB Envigado, Antioquia, Colombia; citizen Colombia; Cedula No. 98517169 (Colombia) (individual) [SDNTK].
ISAZA SANCHEZ, Nelson Dario (a.k.a. “NENE”); DOB 11 Aug 1967; POB Envigado, Antioquia, Colombia; citizen Colombia; Cedula No. 98521489 (Colombia) (individual) [SDNTK].
RUIZ MADRID, Adriana Maria; DOB 14 Dec 1968; POB Envigado, Antioquia, Colombia; citizen Colombia; Cedula No. 42897418 (Colombia) (individual) [SDNTK] (Linked To: CARYTES ENCANTO Y BELLEZA).

UPEGUI GALLEGO, Juan Pablo; DOB 16 Oct 1980; POB Itagui, Antioquia, Colombia; citizen Colombia; Cedula No. 3391839 (Colombia) (individual) [SDNTK] (Linked To: ENVIGADO FUTBOL CLUB S.A.; Linked To: ENFARRADOS COMPANY S.A.S.; Linked To: CENTRO DE DIAGNOSTICO AUTOMOTOR DEL SUR LTDA.).

and entities:

ACUAMATERIALES Y CIA. LIMITADA, Carrera 51 B No. 12 Sur 21 Piso 2, Medellin, Colombia; NIT # 811022933-3 (Colombia) [SDNTK].
CAFETERIA ENVICENTRO, Carrera 48 No. 49 Sur 45, Envigado, Antioquia, Colombia; Matricula Mercantil No 138589 (Aburra Sur) [SDNTK].
CARYTES ENCANTO Y BELLEZA, Calle 6AS 43 A LC 3188, Medellin, Colombia; Centro Comercial Oviedo, Local 3188, El Poblado, Medellin, Colombia; Matricula Mercantil No 40551702 (Medellin) [SDNTK].
CENTRO DE DIAGNOSTICO AUTOMOTOR DEL SUR LTDA. (a.k.a. ENVICENTRO), Carrera 48 No. 49 Sur 45, Envigado, Antioquia, Colombia; NIT # 800233878-1 (Colombia) [SDNTK].
COLOMBIANA DE BIOCOMBUSTIBLES S.A. (a.k.a. COLBIO), Carrera 15 No. 90-66 Int. 103, Medellin, Colombia; Calle 36A Sur No. 46A-81, Centro Comercial Metro Sur, Local 240, Envigado, Antioquia, Colombia; Km. 53 Via Santa Fe de Antioquia, Vereda Ahuyamal, Sopetran, Antioquia, Colombia; Km. 4 Via al Bagre, Caucasia, Antioquia, Colombia; Website http://www.colbio.com; NIT # 900089105-2 (Colombia) [SDNTK].
ENFARRADOS COMPANY S.A.S., Carrera 48 No. 46 Sur 150, Envigado, Antioquia, Colombia; NIT # 900347098-6 (Colombia) [SDNTK].
ENVIGADO FUTBOL CLUB S.A. (a.k.a. ENVIGADO F.C.), Carrera 48 No. 46 Sur 150, Envigado, Antioquia, Colombia; Website http://www.envigadofutbolclub.net; NIT # 900470848-9(Colombia) [SDNTK].
GARCES Y BEDOYA CIA. LTDA, Carrera 50 No. 37-35, Medellin, Colombia; NIT # 800119082-9 (Colombia) [SDNTK].
IMPORTADORA MARENOL LIMITADA, Carrera 50 No. 39-71, Medellin, Colombia; NIT # 800104353-4 (Colombia) [SDNTK].
INVERSIONES C.P.C.L. Y CIA. S. EN C.S., Carrera 48 No. 25 B Sur 12, Envigado, Antioquia, Colombia; NIT # 900315175-8 (Colombia) [SDNTK].
LA TIENDA DE MINGO, Calle 5 D No. 6 125, Medellin, Colombia; Matricula Mercantil No 16218702 (Medellin) [SDNTK].
REPRESENTACIONES MIDAS, Plaza Envigado, Local 89, Envigado, Antioquia, Colombia; Calle 40 Sur No. 40 20, Envigado, Antioquia, Colombia; Matricula Mercantil No 54512 (Aburra Sur) [SDNTK].
ROBIREPUESTOS, Carrera 50 No. 41-41 Local 112, Medellin, Colombia; Matricula Mercantil No 21-438991-02 (Medellin) [SDNTK].
TIENDAS MARGOS (a.k.a. “MARGO'S”), Calle 38A Sur No. 43A 41, Envigado, Antioquia, Colombia; Matricula Mercantil No 5352 (Aburra Sur) [SDNTK].

to the Specially Designated Nationals (SDN) List under its anti-narcotics trafficking sanctions program.

Link:

OFAC Notice