Category Archives: Weapons of Mass Destruction Proliferation Sanctions

01.20.16
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January 17, 2016: Busy weekend for OFAC

On Sunday, OFAC added the following persons:

CHEN, Mingfu; DOB 30 Apr 1980; POB Anhui, China; citizen China; Additional Sanctions Information – Subject to Secondary Sanctions; Passport G22168109 expires 26 Apr 2017; Identification Number 341181198004300019 (China) (individual) [NPWMD] [IFSR] (Linked To: NAVID COMPOSITE MATERIAL COMPANY).
FARAHI, Sayyad Medhi (a.k.a. FARAJZADEH, Seyyed Hadi), Iran; DOB 30 Sep 1960; Additional Sanctions Information – Subject to Secondary Sanctions; Passport G9321488 (Iran) expires 10 Oct 2016 (individual) [NPWMD] [IFSR] (Linked To: MINISTRY OF DEFENSE FOR ARMED FORCES LOGISTICS).
FARGHADANI, Rahimreza (a.k.a. FARGHADANI, Rahim Reza); DOB 16 Aug 1960; alt. DOB 17 Aug 1960; citizen Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Passport 5671711 (Iran) (individual) [NPWMD] [IFSR].
HASHEMI, Seyed Mohammad (a.k.a. HASHEMI, Sayyed Mohammad; a.k.a. HASHEMI, Seyyed Mohammad), Iran; DOB 16 May 1965; citizen Iran; Additional Sanctions Information – Subject to Secondary Sanctions (individual) [NPWMD] [IFSR] (Linked To: MINISTRY OF DEFENSE FOR ARMED FORCES LOGISTICS).
MUSAVI, Sayyed Javad, Iran; DOB 23 Aug 1972; Additional Sanctions Information – Subject to Secondary Sanctions (individual) [NPWMD] [IFSR] (Linked To: SHAHID HEMMAT INDUSTRIAL GROUP).
NOOSHIN, Seyed Mirahmad, Iran; DOB 11 Jan 1966; Additional Sanctions Information – Subject to Secondary Sanctions; Passport G9311208 (Iran) (individual) [NPWMD] [IFSR] (Linked To: SHAHID HEMMAT INDUSTRIAL GROUP).
POURNAGHSHBAND, Hossein (a.k.a. POUR NAGHSH BAND, Hussain Reza; a.k.a. POUR NAGHSHBAND, Hossein; a.k.a. POUR NAGHSHBAND, Hossein Reza); DOB 23 Oct 1965; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Passport E1910843 (Iran) (individual) [NPWMD] [IFSR] (Linked To: NAVID COMPOSITE MATERIAL COMPANY).

and entities:

ANHUI LAND GROUP CO., LIMITED, Shop T18, 3/F, Cathay Pacific 88 Malls, No. 125, Wanchai Road, Wanchai, Hong Kong; Additional Sanctions Information – Subject to Secondary Sanctions; Registration ID 1774300 (Hong Kong) [NPWMD] [IFSR].
CANDID GENERAL TRADING LLC (a.k.a. CANDID TRADING LLC), 3rd Floor, Office No. 306, Al Dana Centre, Al Maktoum Street Deira, Dubai, United Arab Emirates; P.O. Box 41967, Dubai, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR].
MABROOKA TRADING CO L.L.C. (a.k.a. MABROOKA TRADING COMPANY), 3rd Floor, Office No. 306, Al Dana Centre, Al Maktoum Street, Next to Metropolitan Palace Hotel, Al Riqqa, Al Muraqqabat, Deira, Dubai, United Arab Emirates; P.O. Box 33634, Dubai, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions; Registration ID 500871 [NPWMD] [IFSR] (Linked To: NAVID COMPOSITE MATERIAL COMPANY).

to the Specially Designated Nationals List under the weapons of mass destruction non-proliferation sanctions program. Also, OFAC updated this listing:

KETABACHI, Mehrdada Akhlaghi (a.k.a. KETABCHI, Merhdada Akhlaghi), c/o SBIG, Tehran, Iran; DOB 10 Sep 1958; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Passport A0030940 (Iran) (individual) [NPWMD] [IFSR]. -to- KETABACHI, Mehrdada Akhlaghi (a.k.a. KETABCHI, Merhdada Akhlaghi), c/o AIO, Langare Street, Nobonyad Square, Tehran, Iran; c/o SBIG, Tehran, Iran; DOB 10 Sep 1958; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Passport A0030940 (Iran)(individual) [NPWMD] [IFSR].

Link:

OFAC Notice

 

12.09.15
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December 8, 2015: OFAC adds to North Korea, non-proliferation lists

Yesterday, OFAC designated the following persons:

CHOE, Song Il, Vietnam; DOB 08 Jun 1973; citizen Korea, North; Passport 472320665 (Korea, North) expires 26 Sep 2017; alt. Passport 563120356 (Korea, North) issued 19 Mar 2018; Tanchon Commercial Bank Representative in Vietnam (individual) [NPWMD] (Linked To: TANCHON COMMERCIAL BANK).
JANG, Bom Su (a.k.a. JANG, Pom Su), Syria; DOB 15 Apr 1957; citizen Korea, North; Tanchon Commercial Bank Representative in Syria (individual) [NPWMD] (Linked To: TANCHON COMMERCIAL BANK).
JON, Myong Guk (a.k.a. CHO'N, Myo'ng-kuk), Syria; DOB 18 Oct 1976; Passport 4721202031 (Korea, North) expires 21 Feb 2017; Tanchon Commercial Bank Representative in Syria (individual) [NPWMD] (Linked To: TANCHON COMMERCIAL BANK).
KIM, Jung Jong (a.k.a. KIM, Chung Chong), Vietnam; DOB 07 Nov 1966; Passport 199421147 (Korea, North) expires 29 Dec 2014; alt. Passport 381110042 (Korea, North) expires 25 Jan 2016; alt. Passport 563210184 (Korea, North) expires 18 Jun 2018; Tanchon Commercial Bank Representative in Vietnam (individual) [NPWMD] (Linked To: TANCHON COMMERCIAL BANK).
KIM, Kyong Nam (a.k.a. KIM, Kyo'ng-Nam), Russia; DOB 11 Jul 1976; nationality Korea, North; Foreign Trade Bank of the Democratic People's Republic of Korea Representative in Russia (individual) [NPWMD] (Linked To: FOREIGN TRADE BANK OF THE DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA).
KO, Tae Hun (a.k.a. KIM, Myong Gi); DOB 25 May 1972; Passport 563120630 (Korea, North) expires 20 Mar 2018; Tanchon Commercial Bank Representative (individual) [NPWMD] (Linked To: TANCHON COMMERCIAL BANK).

 

and entities:

HAEJIN SHIP MANAGEMENT COMPANY LIMITED, Tonghung-dong, Chung-guyok, Pyongyang, Korea, North; Tonghung-dong, Central District, Pyongyang, Korea, North; Email Address haejinsm@silibank.net.kp; Identification Number IMO 5814866 [DPRK].
PYONGJIN SHIP MANAGEMENT COMPANY LIMITED, Ryukkyo 1-dong, Pyongchon-guyok, Pyongyang, Korea, North; 102 Ryuggyo 1-dong, Pyongchon District, Pyongyang, Korea, North; Identification Number IMO 5817790 [DPRK].
STRATEGIC ROCKET FORCE OF THE KOREAN PEOPLE'S ARMY (a.k.a. STRATEGIC ROCKET FORCE; a.k.a. THE STRATEGIC ROCKET FORCE COMMAND OF KPA; a.k.a. “STRATEGIC FORCE”; a.k.a. “STRATEGIC FORCES”), Pyongyang, Korea, North [NPWMD].
YONGJIN SHIP MANAGEMENT COMPANY LIMITED, Tonghung-dong, Chung-guyok, Pyongyang, Korea, North; Tonghung-dong, Central District, Korea, North; Email Address yonmgjinsm@silibank.net.kp; Identification Number IMO 5814883; alt. Identification Number IMO 5814906; alt. Identification Number IMO 5820255 [DPRK].

under its North Korea and/or non-proliferation sanctions programs.

Link:

OFAC Notice

 

08.10.15
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OFAC fines Production Products $78,750 for WMD sanctions violations

The company sold and shipped 3 duct fabrication machines (worth $500,000) to a SDN List entity (China Precision Machinery Import and Export Corp.) sanctioned under the NPWMD (non-proliferation of weapons of mass destruction) sanctions program without OFAC's authorization. The non-egregious violations were not voluntarily self-reported. The base penalty was $250,000 and the statutory maximum was $1,000,000.

Here's OFAC”s explanation of how they calculated the ultimate settlement amount:

OFAC considered the following to be aggravating factors:

(1) PPI failed to
exercise a minimal degree of caution or care with respect to OFAC sanctions;

(2) PPI had
knowledge that the transaction involved CNPM, a Specially Designated National;

(3) PPI did not
have a sanctions compliance program in place at the time of the transaction; and

(4) the
transaction likely provided economic benefit to a Specially Designated National.

OFAC
considered the following to be mitigating factors:

(1) PPI has not received a Penalty Notice or
Finding of Violation from OFAC in the five years preceding the date of the transaction giving
rise to the Alleged Violations;

(2) PPI is a small, family-owned business with only ten
employees;

(3) PPI took remedial steps to implement a sanctions compliance program; and

(4)
PPI substantially cooperated with OFAC by responding promptly and completely to OFAC’s
additional requests for information and documents.

Link:

OFAC Enforcement Action

 

07.27.15
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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

 

06.23.15
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OFAC Enforcement Action: $391,950 CMP for John Bean Technologies Corporation

The firm shipped goods on a blocked vessel managed by the Islamic Republic of Iran Shipping Lines (IRISL). The base penalty for the non-egregious, non voluntarily self-disclosed violations of Executive Order 13382 and the Weapons of Mass Destruction Non-Proliferation sanctions programs was $670,000. The total transaction amount, including fees paid to various parties, was a tad over $3 million.

Here’s OFAC’s logic in the final penalty amount:

OFAC considered the following to be aggravating factors:

  • (1) With
    respect to counts 2 and 3, JBT management knew of the conduct resulting in the Apparent
    Violations;
  • (2) economic benefit was conferred to a blocked entity, resulting in harm to the
    sanctions program objectives of the Regulations; and
  • (3) JBT is a sophisticated entity that conducts business throughout the world.

OFAC considered the following to be mitigating
factors:

  • (1) JBT has not been the subject of a Penalty Notice or a Finding of Violation from
    OFAC in the five years preceding the transactions constituting the Apparent Violations;
  • (2) JBT
    implemented some remedial measures to prevent a recurrence of the Apparent Violations,
    including employee training, enhancements to its compliance program, and enhanced party
    screening; and
  • (3) JBT cooperated with OFAC’s investigation, including, among other
    cooperation, by agreeing to toll the statute of limitations for 514 days.

Link:

OFAC Enforcement Action

 

04.21.15
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April 3, 2015: OFAC removes Buhary Seyed Abu Tahir from NPWMD program

On April 3rd, OFAC removed the following person from the Non-Proliferation of Weapons of Mass Destruction (NPWMD) program on its Specially Designated Nationals (SDN) List:

TAHIR, Buhary Seyed Abu; DOB 17 Apr 1959; POB Chennai, India; nationality Sri Lanka; Additional Sanctions Information – Subject to Secondary Sanctions; Passport M2068357 (Sri Lanka) issued 04 Sep 2001 expires Sep 2006; alt. Passport M1754102 (Sri Lanka) issued 16 Mar 1999 expires 16 Mar 2004 (individual) [NPWMD] [IFSR].

Link:

OFAC Notice

 

04.09.15
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March 25, 2015: 486 violations net PayPal a $7,658,300 fine

On March 25th, OFAC levied a Civil Monetary Penalty against PayPal for violations of the Iran, Cuba, Sudan, terrorism and Weapons of Mass Destructioin sanctions programs. These violations started in 2009 and occured as recently as September 2013, some of which included explicit references to sanctioned countries (e.g. “Tehran” or “Sudan”).

Here's the detail of one set of violations singled out by OFAC:

Separately, between October 20, 2009 and April 1, 2013, PayPal processed 136 transactions
totaling $7,091.77 to or from a PayPal account registered to Kursad Zafer Cire, an individual
designated by the U.S. State Department on January 12, 2009 pursuant to Executive Order 13382
of June 28, 2005, “Blocking Property of Weapons of Mass Destruction Proliferators and Their
Supporters,” in apparent violation of the WMDPSR. PayPal stated to OFAC that it failed to
identify its customer as a potential Specially Designated National (SDN) at the time of his
designation because the MSB’s automated interdiction filter was not “working properly.”
Starting approximately six months later, PayPal’s automated interdiction filter appropriately
flagged Cire’s account five times (on July 30, 2009, September 3, 2009, October 21, 2009,
October 24, 2009, and November 16, 2009) for potential matches to the SDN, and on each
occasion, separate PayPal Risk Operations Agents dismissed the alerts without requesting
additional information to clear the potential SDN name matches. PayPal stated that this conduct
did not comply with the MSB’s internal policies and procedures for handling SDN name
matches. On February 14, 2013, PayPal’s interdiction filter again flagged Cire’s account for a
sixth time due to a potential match to the SDN, and a PayPal Risk Operations Agent followed the
MSB’s procedures for handling an SDN name match by creating a “case” for the match,
restricting Cire’s account, and requesting additional information from the customer. Upon
receiving the requested information, which included a copy of Cire’s passport showing a date of
birth and place of birth that were identical to those of the SDN, PayPal’s Risk Operations Agent
dismissed the match due to an apparent misunderstanding of why the interdiction filter had
flagged Cire’s account for review. On April 3, 2013, PayPal’s interdiction filter flagged Cire’s
account for a seventh time, and the MSB appropriately blocked the account and reported it to
OFAC.

The total base penalty for all these violations was $17,018,443. Here are OFAC's list of aggravating factors:

1) PayPal’s
management demonstrated reckless disregard for U.S. economic sanctions requirements in
deciding to operate a payment system without implementing appropriate controls to prevent the
system from processing transactions in apparent violation of OFAC regulations;

2) PayPal
management and supervisors knew of the conduct giving rise to the apparent violations;

3)
PayPal’s conduct resulted in harm to U.S. sanctions program objectives, and the MSB provided
economic benefit to Cire and undermined the integrity of the WMDPSR by operating an account
and processing transactions on behalf of an SDN for approximately three-and-a-half years; and

4) PayPal’s OFAC compliance program was inadequate to prevent the apparent violations.

and mitigating factors:

1) PayPal hired new management within its Compliance Division, identified OFAC-related issues with regard to the MSB’s payment system in 2011, and undertook various measures to strengthen PayPal’s OFAC screening processes and measures, including steps to implement more effective controls;

2) PayPal has not received a penalty notice or Finding of Violation in the five years preceding the earliest date of the transactions giving rise to the apparent violations; and

3) PayPal substantially cooperated with OFAC’s investigation, including by submitting the relevant documents and information in a clear and organized fashion, answering numerous follow-up inquiries for information over the course of OFAC’s investigation, and by entering into a statute of limitations tolling agreement and an extension to the agreement.

Links:

OFAC Notice

OFAC Web Notice

OFAC Settlement Agreement