December 11, 2015: Financial Sanctions Alert from Central Bank of Ireland

This is the section about the latest updates:

  • IRAN
  • There have been changes made to the EU Restrictive Measures concerning Iran. Please see links below setting out the changes to the existing anti-proliferation sanctions on Iran:


    Council Regulation (EU) 2015/1861 of 18 October 2015 amending Regulation (EU) No 267/2012 concerning restrictive measures against Iran


    Council Implementing Regulation (EU) 2015/1862 of 18 October 2015 implementing Regulation (EU) No 267/2012 concerning restrictive measures against Iran


  • NEW REGIME Burundi
  • Please note Council Regulation (EU) 2015/1755 of 1 October 2015 concerning concerning restrictive measures in view of the situation in Burundi . This is a new sanctions regime and comes into immediate effect.


  • Other recent Financial Sanctions news is available here.


  • The Central Bank has prepared Frequently Asked Questions (FAQs) to assist credit and financial institutions compliance with financial sanctions requirements.


  • FATF: Financing: FATF Report to G20 Leaders- actions being taken by the FATF


  • FATF: Combating the abuse of non-profit organisations


  • If implemented effectively, targeted financial sanctions are an important means to deprive terrorist and proliferation financiers of their funds, thereby protecting citizens from the threats of crime, terrorism and weapons of mass destruction. International Best Practices: Targeted Financial Sanctions Related to Terrorism and Terrorist Financing (Recommendation 6)


  • Financing of the Terrorist Organisation Islamic State in Iraq and the Levant This study identifies how funds are raised, moved and ultimately used by ISIL. This report seeks to understand how ISIL obtains and moves funds in order to (i) disrupt financial flows, (ii) deprive ISIL of its resources, and (iii) prevent ISIL from abusing relevant financial and economic sectors. Given the diversified nature of ISIL funding and operations, the report considered the broader issue of resourcing to accurately capture the complexities of this terrorist organisation.
  • December 18, 2015: OFAC add to Burundi, Central African Republic sanctions listings

    On Friday, added the following 2 persons to the Central African Republic sanctions list:

    GAYE, Haroun (a.k.a. GAYE, Aroun; a.k.a. GEYE, Aroun; a.k.a. GUAYE, Haroun; a.k.a. GUEYE, Haroun), Bangui, Central African Republic; DOB 30 Jan 1968; alt. DOB 30 Jan 1969; Passport O00065872 (Central African Republic) expires 30 Dec 2019 (individual) [CAR].
    NGAIKOSSET, Eugene Barret (a.k.a. NGAIKOISSET, Eugene; a.k.a. NGAIKOSSE, Eugene Barret; a.k.a. NGAIKOUESSET, Eugene; a.k.a. NGAKOSSET, Eugene; a.k.a. “The Butcher of Paoua”), Bangui, Central African Republic; DOB 08 Oct 1967; alt. DOB 10 Aug 1967; POB Bossangoa, Central African Republic; nationality Central African Republic; Identification Number 911-10-77 (Central African Republic) (individual) [CAR].

    and the following 4 persons to the Burundi sanctions list:

    NDIRAKOBUCA, Gervais (a.k.a. NDIRAKOBUCHA, Gervais; a.k.a. “Ndakugarika”), Burundi; DOB 01 Aug 1970; nationality Burundi; Passport DP0000761; General; Chief of Staff, Ministry of Public Security; Chief of Cabinet for Police Affairs; Burundian National Police Chief of Cabinet (individual) [BURUNDI].
    NGENDAKUMANA, Leonard; DOB 24 Nov 1968; nationality Burundi; Passport DP0000885; General; Burundian National Intelligence Service (SNR) Cabinet Chief (former) (individual) [BURUNDI].
    NIYONZIMA, Joseph (a.k.a. NIJONZIMA, Joseph; a.k.a. NIYONZIMA, Mathias Joseph; a.k.a. NIYONZIMA, Salvator; a.k.a. “Kazungu”), Kinanira III, Kinindo, Bujumbura 257, Burundi; DOB 17 May 1960; alt. DOB 17 Jun 1960; alt. DOB 02 Jan 1967; alt. DOB 06 Mar 1956; POB Bukeye, Burundi; alt. POB Kanyosha Commune, Mubimbi, Bujumbura-Rural Province, Burundi; nationality Burundi; Passport OP0053090 (Burundi); alt. Passport OP0000185 (Burundi) issued 28 Jul 2011 expires 28 Jul 2016 (individual) [BURUNDI].

    SINDUHIJE, Alexis (a.k.a. SINHUHIJE, Alexis); DOB 05 May 1967; alt. DOB 05 May 1966; POB Kamenge, Bujumbura, Burundi; nationality Burundi; Gender Male (individual) [BURUNDI].

    Link:

    OFAC Notice

     

    December 8, 2015: SECO joins the Burundi sanctions party!

    Yesterday, Swiss regulators added sanctions against Burundi and designated the following individuals:

    SSID: 25-32655 Name: Godefroid Bizimana

    DOB: 23 Apr 1968 POB: Nyagaseke, Mabayi, Cibitoke Nationality: Burundi Identification
    document:
    Passport No. DP0001520, Burundi

    Justification: Deputy Director-General of the National Police, responsible for undermining
    democracy by making operational decisions that have led to a disproportionate use of force
    and acts of violent repression towards peaceful demonstrations that started on 26 Apr 2015
    following the announcement of the presidential candidacy of President Nkurunziza.
    Modifications: Listed on 4 Dec 2015

    SSID: 25-32664 Name: Gervais Ndirakobuca

    DOB: 1 Aug 1970 Good quality a.k.a.: Ndakugarika Nationality: Burundi Identification
    document:
    Passport No. DP0000761, Burundi

    Justification: Head of Cabinet of the Presidential Administration (Présidence) responsible
    for matters relating to the National Police. Responsible for obstructing the search for a
    political solution in Burundi by issuing instructions that led to disproportionate use of force,
    acts of violence, acts of repression and violations of international human rights law against
    protestors demonstrating from 26 Apr 2015 onwards, following the announcement of the
    presidential candidacy of President Nkurunziza, including on 26, 27 and 28 Apr in the
    Nyakabiga and Musaga districts in Bujumbura.
    Modifications: Listed on 4 Dec 2015

    SSID: 25-32672 Name: Mathias Joseph Niyonzima

    Good quality a.k.a.: Kazungu Identification document: a) Other No. O/00064, Burundi
    (registration number SNR)
    b) Passport No. OP0053090, Burundi

    Justification: Officer of the National Intelligence Service. Responsible for obstructing the
    search for a political solution in Burundi by inciting violence and acts of repression during the
    demonstrations that started on 26 Apr 2015 following the announcement of the presidential
    candidacy of President Nkurunziza. Responsible for helping train, coordinate and arm the
    Imbonerakure paramilitary militias, including outside Burundi, who are responsible for acts of
    violence, repression and serious human rights abuses in Burundi.
    Modifications: Listed on
    4 Dec 2015

    SSID: 25-32679 Name: Léonard Ngendakumana

    DOB: 24 Nov 1968 Nationality: Burundi Identification document: Passport No.
    DP0000885, Burundi

    Justification: Former ‘Chargé de Missions de la Présidence’ and former army general.
    Responsible for obstructing the search for a political solution in Burundi by participating in
    the attempted coup d'état of 13 May 2015 to overthrow the Burundi Government.
    Responsible for acts of violence
    grenade attacks committed in Burundi, as well as for
    incitement to violence. General Léonard Ngendakumana publicly supported violence as a
    means to achieve political goals.
    Modifications: Listed on 4 Dec 2015

    Links:

    FINMA Notice

    Data files of listings – PDF, XML

     

    November 23, 2015: OFAC adds Burundi sanctions program

    Yesterday, President Obama established a new targeted sanctions program against persons in Burundi through a new Executive Order titled “Blocking Property of Certain Persons Contributing to the Situation in Burundi”. Concurrent with that, OFAC christened the newborn program by designating the following 4 persons:

    BIZIMANA, Godefroid, Kinanira IV, Bujumbura, Burundi; DOB 23 Apr 1968; Diplomatic Passport DP0001520 (Burundi) issued 01 Aug 2012 expires 01 Aug 2017 (individual) [BURUNDI].
    BUNYONI, Alain Guillaume (a.k.a. BUNYONI, Allain Guillaume), 143 Avenue Gasekebuye, Commune Urbaine de Musaga, Bujumbura, Bujumbura 1870, Burundi; DOB 02 Jan 1972; POB Bujumbura, Burundi; nationality Burundi; National ID No. 0201184751 (Burundi); Diplomatic Passport DP0001842 (Burundi) issued 08 Apr 2013 expires 08 Apr 2018; Minister of Public Security (individual) [BURUNDI].
    NDAYIRUKIYE, Cyrille; DOB 08 Jul 1954; POB Kiganda, Burundi; nationality Burundi; Gender Male; Passport DP0001029 (Burundi) issued 24 Oct 2011 expires 24 Oct 2016; Former Defense Minister (individual) [BURUNDI].
    NIYOMBARE, Godefroid, Kinanira 4, Bujumbura, Bujumbura, Burundi; DOB 18 Oct 1969; POB Bujumbura, Burundi; nationality Burundi; Gender Male; Passport PD007079 (Burundi) issued 01 Jun 2010 expires 01 Jun 2015; National ID No. 0201CNI189976; Major General (individual) [BURUNDI].

    The broad class of targeted people includes those who, according to the Executive Order:

    (1)  actions or policies that threaten the
         peace, security, or stability of Burundi;
         (2)  actions or policies that undermine
         democratic processes or institutions in
         Burundi;
    
         (3)  human rights abuses;
         (4)  the targeting of women, children, or
         any civilians through the commission of acts
         of violence (including killing, maiming,
         torture, or rape or other sexual violence),
         abduction, forced displacement, or attacks
         on schools, hospitals, religious sites, or
         locations where civilians are seeking
         refuge, or through other conduct that may
         constitute a serious abuse or violation of
         human rights or a violation of international
         humanitarian law;
         (5)  actions or policies that prohibit,
         limit, or penalize the exercise of freedom
         of expression or freedom of peaceful
         assembly;
         (6)  the use or recruitment of children by
         armed groups or armed forces;
         (7)  the obstruction of the delivery or
         distribution of, or access to, humanitarian
         assistance; or
         (8)  attacks, attempted attacks, or threats
         against United Nations missions, international security presences, or other
    
                        peacekeeping operations;
                   

    There are clauses for leaders of groups who commit these acts, people who materially assist or finance these persons, groups and activities, and the “owned or controlled” language that leads you to the OFAC 50% Rule.

    Links:

    OFAC Notice

    Executive Order

     

    October 9, 2015: Finnish regulatory updates

    On a regular basis, Finnish regulators publish EU sanctions compliance links. Here is the October 9th, 2015 edition:

    Link:

    Finnish regulatory update

     

    October 2, 2015: EU, HMT implement sanctions on Burundi

    On Friday, Her Majesty's Treasury (HMT) implemented Council Implementing Regulation (EU) No 2015/1755, which establishes the following persons:

    1. Name: BIZIMANA 1: GODEFROID

    DOB: 23/04/1968. POB: Nyagaseke, Mabayi, Cibitoke Nationality: Burundian Passport
    Details: Passport number: DP0001520 Position: Deputy Director-General of the National
    Police Other Information: Deputy Director-General of the National Police Listed on:
    02/10/2015 Last Updated: 02/10/2015 Group ID: 13281.

    2. Name: NDIRAKOBUCA 1: GERVAIS

    DOB: 01/08/1970. a.k.a: NDAKUGARIKA Nationality: Burundian Passport Details:
    Passport number: DP0000761 Position: Head of Cabinet of the Presidential Administration
    (Présidence) responsible for matters relating to the National Police Listed on: 02/10/2015
    Last Updated: 02/10/2015 Group ID: 13282.

    3. Name: NGENDAKUMANA 1: LÉONARD

    DOB: 24/11/1968. Nationality: Burundian Passport Details: Passport number:
    DP0000885 Position:
    Former ‘Chargé de Missions de la Présidence’ and former army
    general. Listed on: 02/10/2015 Last Updated: 02/10/2015 Group ID: 13284.

    4. Name: NIYONZIMA 1: MATHIAS 2: JOSEPH a.k.a: KAZUNGU

    Nationality: Burundian Passport Details: Passport number: OP0053090 Position: Officer of
    the National Intelligence Service Other Information: Registration number (SNR): O/00064
    Listed on: 02/10/2015 Last Updated: 02/10/2015 Group ID: 13283.

    as subject to sanctions under the new Burundi sanctions program.

    Links:

    HMT Notice

    Council Implementing Regulation (EU) No 2015/1755

     

    October 1, 2015: EU statement of Burundi sanctions adoption

    The Council adopted travel restrictions and an asset freeze in respect of four persons whose activities are undermining democracy or obstructing efforts to achieve a political solution to the current crisis in Burundi, in particular through acts of violence, repression or incitement to violence, including acts which constitute serious human rights violations.

    The EU has repeatedly called on all parties to refrain from, and condemn, any acts of violence. Progress is not being made in the search for a political solution to the crisis in Burundi and there is a risk of an escalation of violence. This is why the Council has considered it appropriate to impose restrictive measures on individuals.

    The legal acts, including the details of those targeted by the restrictions, are published in the EU Official Journal of 2 October 2015.

    These measures form part of the EU's action in support of efforts by the international community, and particularly by the East African Community and the African Union, to achieve a lasting political solution through an inter-Burundian dialogue. This approach also takes account of the obligations stemming from the Cotonou Agreement concerning respect for human rights, democratic values and the rule of law, and, in this context, of the possibility of starting the consultation procedures laid down in the Agreement, inter alia in Article 96.

    Link:

    EU Notice