On Tuesday, Swiss regulators amended a whole slew of persons and entities sanctioned under the Syrian sanctions program – it's a 34-page PDF, so Mr. Watchlist will not list the contents here. However, he will note that many of the listings don't have any change notation, so it's not clear what changed.
Links:
Data files of updates – PDF, XML
Last Friday, Her Majesty's Treasury (HMT) implemented Council Implementing Regulation (EU) No 2015/2350 by removing the following person:
HAMSHO, Samir
DOB: 01/03/1972. a.k.a: (1) HAMCHO, Samir (2) HAMCHU,
Samir (3) HAMISHO, Samir (4) HEMASHO, Samir (5) HMEISHO,
Samir (6) HMICHO, Samir (7) HMISHO, Samir
Samir (3) HAMISHO, Samir (4) HEMASHO, Samir (5) HMEISHO,
Samir (6) HMICHO, Samir (7) HMISHO, Samir Passport Details: (1) N008803455
(Syrian), (2) YA056959 (Brazilian). Address: (1) 16 Martello Road, Poole, United
Kingdom, BH13 7DH. (2) 290 Qura Al Assad, Damascus, Syria. (3) Hamsho
Building, 31 Baghdad Street, Damascus, Syria. Position: Owner and chairman of Al
Buroj and Syria Steel/Hmisho Steel. Other Information: Also known as Samer or
Sameer. Prominent Syrian businessman. Al Buroj and Syria Steel/Hmisho Steel are
subsidiaries of Hamsho Trading, a subsidiary of Hamsho International. Listed on:
09/03/2015 Last Updated: 18/12/2015 Group ID: 13234.
and two entities:
AL BUROJ TRADINGa.k.a: Borouj Trading Company Address: Hamsho Building, 31 Baghdad Street,
Damascus, Syria. Other Information: Subsidiary of Hamsho Trading and therefore
ultimately of Hamsho International. Al Buroj Trading is associated with Hamsho
International. Listed on: 09/03/2015 Last Updated: 18/12/2015 Group ID: 13239.SYRIA STEEL SAa.k.a: (1) Hmisho Steel (2) Syria Steel Co. (3) Syria Steel RollingMill Address: Hamsho Building, 31 Baghdad Street, Damascus, Syria. Other
Information: Subsidiary of Hamsho Trading and therefore ultimately a subsidiary
of Hamsho International. Listed on: 09/03/2015 Last Updated: 18/12/2015 Group
ID: 13238.
from their Syrian sanctions list:
Links:
Barracuda Networks allegedly violated the Iranian, Sudanese and Syrian sanctions programs by selling and providing updates to web filtering products that could be used to block and censor Internet content and Internet security software from August 2009 to May 2012 to blocked persons, including people on the SDN List under the Syrian sanctions program. The base penalty for these voluntarily self-disclosed, non-egregious violations is $123, 586.
Here is OFAC's accounting of the General Factors considered in coming up with the settlement amount:
(1) Barracuda acted with reckless disregard for sanctions requirements
by(a) permitting distributors and resellers to sell its products and updates to SDNs and to
customers in sanctioned countries when it knew or had reason to know that the products were
located in sanctioned countries or with SDNs, in potential violation of U.S. sanctions
requirements, and(b) distributing its products and technology to more than 17,000 resellers and
distributors worldwide without implementing any written sanctions compliance policies or
procedures, and failing to provide training to its employees regarding export controls and
sanctions;(2) Barracuda knew or had reason to know that it was exporting goods, technology,
and services to Iran and Sudan because IP addresses associated with those countries were used to
contact the company; further, Barracuda knew or had reason to know that it was exporting technology to Syrian SDNs because the SDNs were listed on sales invoices;(3) the exportation
of the Web filtering software and hardware to Iran, Sudan, and SDNs in Syria could potentially
have caused significant harm to U.S. sanctions program objectives because the technology could
have been used to block or censor Internet activity;2(4) Barracuda did not screen IP addresses
used to contact Barracuda’s servers because it had no OFAC compliance program in place at the
time of the transactions;(5) Barracuda has no prior OFAC sanctions history, including no
penalty notice or Finding of Violation in the five years preceding the earliest date of the
transactions giving rise to the apparent violations, making it eligible for up to 25 percent “first
offense” mitigation;(6) Barracuda took significant remedial steps including developing a method
to disable products in sanctioned countries, prioritizing U.S. sanctions and export controls
compliance by establishing an Office of Trade Compliance and hiring a general counsel with
subject matter expertise in these areas, issuing company-wide a statement from the CEO about
sanctions-related policy, implementing a trade compliance manual, and enhancing its sales
software to include red flags for orders that may require a license; and(7) Barracuda
substantially cooperated with OFAC’s investigation, including by agreeing to toll the statute of
limitations for approximately 521 days.
That statute of limitations tolling is for a bit shy of 1 1/2 years. This is also the first time Mr. Watchlist has seen OFAC refer to the “first offense” discount (it's in the Enforcement Guidelines).
Link:
Today, OFAC designated these persons:
HASWANI, George (a.k.a. AL HASAWANI, George; a.k.a. HASAWANI, George; a.k.a. HASWANI, Jurj; a.k.a. HESSWANI, Georges; a.k.a. HESWANI, George; a.k.a. HEWANI, George; a.k.a. KHESOUANI, George; a.k.a. KHESOUANI, Georges); DOB 26 Sep 1946; POB Yabrud, Syria; nationality Syria; alt. nationality Russia (individual) [SYRIA].ILYUMZHINOV, Kirsan Nikolayevich (a.k.a. ILYUMZHINOV, Kirsan); DOB 05 Apr 1962; POB Elista, Republic of Kalmykia, Russia (individual) [SYRIA] (Linked To: MAYALEH, Adib; Linked To: RIDA, Batoul).KHURI, Mudalal (a.k.a. KHOURY, Mudallal; a.k.a. KHURI, Mudalal Mtanyus); DOB 18 Jun 1957; POB Khoms, Syria; nationality Russia (individual) [SYRIA] (Linked To: MAYALEH, Adib; Linked To: RIDA, Batoul).NICOLAOU, Nicos; DOB 06 Apr 1965; POB Cyprus; nationality Cyprus (individual) [SYRIA] (Linked To: IOANNOU, Ioannis; Linked To: PIRUSETI ENTERPRISES LTD; Linked To: KHURI, Mudalal).
and these entities:
EZEGOO INVESTMENTS LTD, 1 Logothetou, Lemesos 4043, Cyprus; National ID No. C310521 (Cyprus) [SYRIA] (Linked To: IOANNOU, Ioannis; Linked To: KHURI, Mudalal; Linked To: NICOLAOU, Nicos; Linked To: PRIMAX BUSINESS CONSULTANTS LIMITED).HESCO ENGINEERING & CONSTRUCTION CO (a.k.a. HESCO ENG & CON. CO; a.k.a. HESCO ENGINEERING AND CONSTRUCTION COMPANY LIMITED), Al Horani Building, Abdullah Ben Omer Street, Damascus, Syria; Suite 351, 10 Great Russell Street, London WC1B 3BQ, United Kingdom; Company Number 05527424 (United Kingdom) [SYRIA] (Linked To: HASWANI, George).HUDSOTRADE LIMITED, 118 Anexartisias Street, Suite 202, Limassol 3040, Cyprus; 14 Gubkina Street, Moscow, Moscow Region 117312, Russia; Website http://www.primax.com.cy; Registration ID C81329 (Cyprus) [SYRIA] (Linked To: KHURI, Mudalal; Linked To: NICOLAOU, Nicos; Linked To: PRIMAX BUSINESS CONSULTANTS LIMITED).KREMSONT COMMERCIAL INC. (a.k.a. KREMSONT ALLIANCE CORP.), Corner of Eyre Street and Hutson Street, Blake Building, No. 302, Belize City, Belize [SYRIA] (Linked To: KHURI, Mudalal).PRIMAX BUSINESS CONSULTANTS LIMITED, 118 Anexartisias Street, 2nd Floor, Apt/Office 202, Limassol, Cyprus; Registration ID HE 143062 (Cyprus) [SYRIA] (Linked To: KHURI, Mudalal; Linked To: NICOLAOU, Nicos).RUSSIAN FINANCIAL ALLIANCE BANK (a.k.a. OPEN JOINT STOCK COMPANY JOINT STOCK COMMERCIAL BANK 'RUSSIAN FINANCIAL ALLIANCE'; a.k.a. RFA BANK; a.k.a. “AKB RFA, OAO”; a.k.a. “OJSC JSCB RFA”), per. Maly Karetny, d. 11-13, str. 1, Moscow 127051, Russia; SWIFT/BIC MNGRRUMM; Website http://www.rfabank.ru; all offices worldwide [SYRIA] (Linked To: KHURI, Mudalal; Linked To: ILYUMZHINOV, Kirsan Nikolayevich).
under their Syria sanctions program.
Link:
Link:
On July 3rd, the General Court of the European Union annulled the designation of the following person, designated under the EU's (and HMT's) Syrian sanctions:
AL-SHAAR, Mohammad, Nidal
Title: Dr DOB: –/–/1956. POB: Aleppo a.k.a: (1) AL CHA'AR, Mohamed, Nidal (2) AL
CHA'AR, Mohammad, Nidal (3) AL CHA'AR, Mohammed, Nidal (4) AL CHA'AR,
Muhammad, Nidal (5) AL SHA'AR, Mohamed, Nidal (6) AL SHA'AR, Mohammad,
Nidal (7) AL SHA'AR, Mohammed, Nidal (8) AL SHA'AR, Muhammad, Nidal (9) AL-
CHAAR, Mohamed, Nidal (10) AL-CHAAR, Mohammad, Nidal (11) AL-CHAAR,
Mohammed, Nidal (12) AL-CHAAR, Muhammad, Nidal (13) AL-SHAAR, Mohamed,
Nidal (14) AL-SHAAR, Mohammed, Nidal (15) AL-SHAAR, Muhammad, Nidal Other
Information: Former Minister of Economy and Trade Listed on: 02/12/2011 Last
Updated: 28/09/2015 Group ID: 12413
It was not appealled (you have 2 months and 10 days to appeal), so the designation removal was published in the EU Official Journal on August 25th. Note: the notice from HMT puts these dates in 2014, which makes no sense – I assume it was a typo. And the date math from July 3rd to August 25th doesn't make sense, either – unless they were giving notice that the designation was going to come off in mid-to-late September.
Link:
General Court of the European Union judgment
On Monday, OFAC designated the following persons:
AYDIN, Mustafa, Turkey; DOB 26 May 1988; Passport U04663595 (Turkey) (individual) [SYRIA] (Linked To: MILENYUM ENERGY S.A.; Linked To: BLUE ENERGY TRADE LTD. CO.; Linked To: ABDULKARIM GROUP).DUZGOREN, Erkan, Turkey; DOB 17 Jun 1980 (individual) [SYRIA] (Linked To: MILENYUM ENERGY S.A.).DUZGOREN, Serkan, Turkey; DOB 28 Jan 1979 (individual) [SYRIA] (Linked To: MILENYUM ENERGY S.A.).KENAR, Ufuk, Turkey; DOB 24 Apr 1980 (individual) [SYRIA] (Linked To: MILENYUM ENERGY S.A.).
and entities:
AQUA SHIPPING LTD. (a.k.a. AQUA SHIPPING LTD.-MAI), c/o Milenyum Denizcilik Gemi Hizmetleri Acentelik ve Ozel Ogretim Hizmetleri Ltd. Sti, Nazli Sokak 9, Halilrifatpasa Mah, Sisli, Istanbul 34384, Turkey; Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands; Identification Number IMO 5849194 [SYRIA] (Linked To: MILENYUM ENERGY S.A.).BLUE ENERGY TRADE LTD. CO., P.O. Box 556, Charlestown, Saint Kitts and Nevis [SYRIA] (Linked To: MILENYUM ENERGY S.A.).EBLA TRADE SERVICES S.A.L./OFF-SHORE, Beirut, Lebanon; Nakhle Center, Property Number: 295/24, Baabda, Furn, Chebbak, Lebanon [SYRIA] (Linked To: MILENYUM ENERGY S.A.; Linked To: BLUE ENERGY TRADE LTD. CO.).GENERAL DIRECTORATE OF SYRIAN PORTS (a.k.a. “GENERAL DIRECTORATE OF PORTS”), Algazaer Street, Lattakia, Syria [SYRIA].GREEN SHIPPING LTD., c/o Milenyum Denizcilik Gemi Hizmetleri Acentelik ve Ozel Ogretim Hizmetleri Ltd. Sti, Nazli Sokak 9, Halilrifatpasa Mah, Sisli, Istanbul 34384, Turkey; Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands; Identification Number IMO 5848165 [SYRIA] (Linked To: MILENYUM ENERGY S.A.).LATTAKIA PORT GENERAL COMPANY (a.k.a. LATAKIA PORT GENERAL COMPANY), BP 220, Latakia, Syria; Postal Box 220, Lattakia, Syria; Baghdad Street, Lattakia, Syria [SYRIA].MILENYUM ENERGY S.A. (a.k.a. MILENYUM DENIZCILIK GEMI; a.k.a. MILENYUM DENIZCILIK GEMI HIZMETLERI ACENTELIK VE OZEL OGRETIM HIZMETLERI LIMITED SIRKETI; a.k.a. MILENYUM SHIPPING), c/o Milenyum Denizcilik Gemi H., Hizmetleri Ltd. Sti, Nazli Sokak 9, Halilrifatpasa Mah, Sisli, Istanbul 34384, Turkey; Ataturk Mahallesi Gulay Sokak, No. 12/3, Atasehir, Istanbul, Turkey; No. 18 D. 1 Kemankes Mah. Necatibey Cad., Akce Sok., Karakoy, Istanbul, Turkey; Sierra Leone; Avenida Norte Enrique Geenzeier El Cangrejo, Panama 0834-1082, Panama; Website http://www.milenyumshipping.com; Company Number 792313 (Panama) [SYRIA] (Linked To: ABDULKARIM, Wael; Linked To: ABDULKARIM GROUP).MORGAN ADDITIVES MANUFACTURING CO. (a.k.a. MORGAN MIDDLE EAST LLC), Office No. 2206, 22nd Floor, Jafza View 19, Sheikh Zayed Road Besides Jafza View 18, Jebel Ali Free Zone Authority, Dubai, United Arab Emirates; Suite 13, First Floor, Oliaji Trade Centre, Francis Rachel Street, Victoria, Mahe, Seychelles; Website http://www.morganme.com; alt. Website morgan.ae [SYRIA] (Linked To: ABDULKARIM, Wael).SYRIAN CHAMBER OF SHIPPING (a.k.a. “SCOS”), Al Jazaeer Street, Farid Hanna Bldg, 8th Fl., P.O. Box 1731, Lattakia, Syria; Al Mina Street, Tartous, Syria [SYRIA].SYRIAN GENERAL AUTHORITY FOR MARITIME TRANSPORT (a.k.a. SYRIAMAR; a.k.a. SYRIAN GENERAL ESTABLISHMENT FOR MARINE TRANSPORT; a.k.a. SYRIAN GENERAL ORGANIZATION FOR MARITIME TRANSPORT), BP 28, Bur Sa'id Street, Latakia, Syria; BP 225, Yarmouk Street, Latakia, Syria; BP 915, al-Mina Street, Tartous, Syria; BP 730, Argentine Street, Damascus, Syria; Port Road, Lattakia, Syria [SYRIA].SYRIAN SHIPPING AGENCIES COMPANY (a.k.a. “SHIPCO”; a.k.a. “SHIPPING AGENCIES CO.”), Port Said Street, P.O. Box 28, Lattakia, Syria; Port Street, P.O. Box 3, Tartous, Syria; Joul Jammal Street, P.O. Box 28, Banias, Syria; Brazil Street, P.O. Box 12477, Damascus, Syria [SYRIA].TARTOUS PORT GENERAL COMPANY, Al Mina Street, Tartous, Syria; Postal Box 86, Tartous, Syria [SYRIA].THE EAGLES L.L.C. (a.k.a. THE EAGLES INTERNATIONAL LLC), Plot No. 41, Airport Free Trade Zone, Damascus, Syria [SYRIA] (Linked To: ABDULKARIM, Wael; Linked To: ABDULKARIM GROUP).
and vessels:
AQUA Sierra Leone flag; Vessel Registration Identification IMO 7529641 (vessel) [SYRIA] (Linked To: MILENYUM ENERGY S.A.; Linked To: AQUA SHIPPING LTD.).BLUE DREAM Saint Kitts and Nevis flag; Vessel Registration Identification IMO 8002664 (vessel) [SYRIA] (Linked To: MILENYUM ENERGY S.A.).BLUE WAY Panama flag; Vessel Registration Identification IMO 8800298 (vessel) [SYRIA] (Linked To: MILENYUM ENERGY S.A.).BLUEGAS Sierra Leone flag; Vessel Registration Identification IMO 7909839 (vessel) [SYRIA] (Linked To: MILENYUM ENERGY S.A.).FINIKIA; Vessel Registration Identification IMO 9385233 (vessel) [SYRIA] (Linked To: SYRIAN GENERAL AUTHORITY FOR MARITIME TRANSPORT).GREEN LIGHT Panama flag; Vessel Registration Identification IMO 8810700 (vessel) [SYRIA] (Linked To: MILENYUM ENERGY S.A.; Linked To: GREEN SHIPPING LTD.).LAODICEA; Vessel Registration Identification IMO 9274343 (vessel) [SYRIA] (Linked To: SYRIAN GENERAL AUTHORITY FOR MARITIME TRANSPORT).MARIANA Sierra Leone flag; Vessel Registration Identification IMO 8016835 (vessel) [SYRIA] (Linked To: MILENYUM ENERGY S.A.).SOURIA; Vessel Registration Identification IMO 9274331 (vessel) [SYRIA] (Linked To: SYRIAN GENERAL AUTHORITY FOR MARITIME TRANSPORT).TALA Panama flag; Vessel Registration Identification IMO 8012114 (vessel) [SYRIA] (Linked To: MILENYUM ENERGY S.A.).
under its Syrian sanctions program. It's interesting to note, by the way, which countries have no compunction offering flagging services to the Syrians.
Link: