Buh-bye! OFAC calls it quits with Cuba, Narcotics, Iran listings

Earlier today, OFAC removed the following sanctions listings from its SDN List:

URREGO ESCUDERO, Carlos Agustin (a.k.a. BENALCAZAR FURMAN, Moshe), Colombia; DOB 19 Feb 1976; citizen Colombia; Cedula No. 79928745 (Colombia); Passport AF392658 (Colombia) (individual) [SDNTK].
BENALCAZAR FURMAN, Moshe (a.k.a. URREGO ESCUDERO, Carlos Agustin), Colombia; DOB 19 Feb 1976; citizen Colombia; Cedula No. 79928745 (Colombia); Passport AF392658 (Colombia) (individual) [SDNTK].
HANDAL LARACH, Jose Miguel, San Pedro Sula, Cortes, Honduras; DOB 18 Jan 1941; citizen Honduras; National ID No. 0401-1941-00086 (Honduras) (individual) [SDNTK] (Linked To: AUTO PARTES HANDAL S. DE R.L. DE C.V.; Linked To: SUPERTIENDAS HANDAL S. DE R.L.; Linked To: RANCHO LA HERRADURA).
DETTIN SPA, Via Campania, 9-36015, Schio, Italy [ISA].
AGUIAR, Raul, Avenida de Concha, Espina 8, E-28036, Madrid, Spain; Director, Banco Nacional de Cuba (individual) [CUBA].
ALVAREZ AGUIRRE, Manuel, Panama (individual) [CUBA].
CHAO, Lazaro R., 20 Ironmonger Lane, London EC2V 8EY, United Kingdom; Executive Director, Havana International Bank (individual) [CUBA].
COLON BETANCOURT, Eduardo, Panama (individual) [CUBA].
IMPERATORI, Julio A., 20 Ironmonger Lane, London EC2V 8EY, United Kingdom; Managing Director, Havana International Bank (individual) [CUBA].
LEBREDO, Jose A., Zweierstrasse 35, Zurich CH-8022, Switzerland; Director, Banco Nacional de Cuba (individual) [CUBA].
LOBATO, Julio (a.k.a. PRADO, Julio), Panama (individual) [CUBA].
PRADO, Julio (a.k.a. LOBATO, Julio), Panama (individual) [CUBA].
LOPEZ, Miguel A., 20 Ironmonger Lane, London EC2V 8EY, United Kingdom; Deputy Chairman, Havana International Bank (individual) [CUBA].
PENA TORRES, Jose, Panama (individual) [CUBA].
PEREZ CRUZ, Osvaldo, Panama (individual) [CUBA].
REYES VERGARA, Guillermo, Panama City, Panama (individual) [CUBA].
ROCHA, Antonio, Panama City, Panama (individual) [CUBA].
RODRIQUEZ BORGES, Jesus (a.k.a. RODRIQUEZ BORJES, Jesus), Panama (individual) [CUBA].
RODRIQUEZ BORJES, Jesus (a.k.a. RODRIQUEZ BORGES, Jesus), Panama (individual) [CUBA].
RODRIQUEZ, Jose Julio, 20 Ironmonger Lane, London EC2V 8EY, United Kingdom; Chairman, Havana International Bank (individual) [CUBA].
RUIZ POO, Ramon Miguel, Panama (individual) [CUBA].
TOLEDO, R.F., 20 Ironmonger Lane, London EC2V 8EF, United Kingdom; Managing Director, Havana International Bank (individual) [CUBA].
TORRES, Manuel, Federico Boyd Avenue & 51 Street, Panama City, Panama; Representative, Banco Nacional de Cuba (individual) [CUBA].
TOSCO GARCIA, Arnaldo, Panama (individual) [CUBA].
VAZ, Jose, 20 Ironmonger Lane, London EC2V 8EY, United Kingdom; Managing Director, Havana International Bank (individual) [CUBA].

These were designated under the Counter-Narcotics Trafficking (3), Iran Sanctions Act (1) and Cuban (all the rest) sanctions programs.

Link:

OFAC Notice

 

Associated Shipbroking cleans up its act

On Thursday, OFAC removed the following company (listed under two similar names) from its Iran Sanctions Act program:

ASSOCIATED SHIPBROKING (a.k.a. ASSOCIATED SHIPBROKING S.A.M.), Gildo Pastor Center – Block C 4.20, 7 rue du Gabian, Fontvieille MC 98000, Monaco; Website http://www.associated-shipbroking.mc [ISA].

ASSOCIATED SHIPBROKING S.A.M. (a.k.a. ASSOCIATED SHIPBROKING), Gildo Pastor Center – Block C 4.20, 7 rue du Gabian, Fontvieille MC 98000, Monaco; Website http://www.associated-shipbroking.mc [ISA].

Link:

OFAC Notice

 

Regulatory Spotlight: Iran Sanctions Act of 1996 (Part 1)

Today, the why. Congress made the following findings:

(1) The efforts of the Government of Iran to acquire weapons of mass destruction and themeans to deliver them and its support of acts of international terrorism endanger the nationalsecurity and foreign policy interests of the United States and those countries with which theUnited States shares common strategic and foreign policy objectives.

(2) The objective of preventing the proliferation of weapons of mass destruction and acts ofinternational terrorism through existing multilateral and bilateral initiatives requires additionalefforts to deny Iran the financial means to sustain its nuclear, chemical, biological, and missileweapons programs.

(3) The Government of Iran uses its diplomatic facilities and quasi-governmental institutionsoutside of Iran to promote acts of international terrorism and assist its nuclear, chemical,biological, and missile weapons programs.

And therefore made the following policy statement:

The Congress declares that it is the policy of the United States to deny Iran the ability to supportacts of international terrorism and to fund the development and acquisition of weapons of massdestruction and the means to deliver them by limiting the development of Iran's ability to explorefor, extract, refine, or transport by pipeline petroleum resources of Iran.

When will the Iran Sanctions Act (ISA) stop being enforced? See Section 8:

The requirement under section 5(a) to impose sanctions shall no longer have force oreffect with respect to Iran if the President determines and certifies to the appropriatecongressional committees that Iran–

(1) has ceased its efforts to design, develop, manufacture, or acquire–

(A) a nuclear explosive device or related materials and technology;

(B) chemical and biological weapons; and

(C) ballistic missiles and ballistic missile launch technology;

(2) has been removed from the list of countries the governments of which have beendetermined, for purposes of section 6(j) of the Export Administration Act of 1979, to haverepeatedly provided support for acts of international terrorism; and

(3) poses no significant threat to United States national security, interests, or allies.

The ISA is structured a little funny – the reporting requirements (Section 4) being enumerated earlier than the actual description of sanctions and whom they're applicable to (Sections 5 and 6). Subsequent posts will cover the remainder of the Act, even though some of this was covered in an earlier post on what the ISA sanctions actually were.

Next up: when will sanctions be applied?

Link:

Iran Sanctions Act of 1996

 

Regulatory Spotlight: Iran Sanctions Act of 1996 (Part 1)

Today, the why. Congress made the following findings:

(1) The efforts of the Government of Iran to acquire weapons of mass destruction and themeans to deliver them and its support of acts of international terrorism endanger the nationalsecurity and foreign policy interests of the United States and those countries with which theUnited States shares common strategic and foreign policy objectives.

(2) The objective of preventing the proliferation of weapons of mass destruction and acts ofinternational terrorism through existing multilateral and bilateral initiatives requires additionalefforts to deny Iran the financial means to sustain its nuclear, chemical, biological, and missileweapons programs.

(3) The Government of Iran uses its diplomatic facilities and quasi-governmental institutionsoutside of Iran to promote acts of international terrorism and assist its nuclear, chemical,biological, and missile weapons programs.

And therefore made the following policy statement:

The Congress declares that it is the policy of the United States to deny Iran the ability to supportacts of international terrorism and to fund the development and acquisition of weapons of massdestruction and the means to deliver them by limiting the development of Iran's ability to explorefor, extract, refine, or transport by pipeline petroleum resources of Iran.

When will the Iran Sanctions Act (ISA) stop being enforced? See Section 8:

The requirement under section 5(a) to impose sanctions shall no longer have force oreffect with respect to Iran if the President determines and certifies to the appropriatecongressional committees that Iran–

(1) has ceased its efforts to design, develop, manufacture, or acquire–

(A) a nuclear explosive device or related materials and technology;

(B) chemical and biological weapons; and

(C) ballistic missiles and ballistic missile launch technology;

(2) has been removed from the list of countries the governments of which have beendetermined, for purposes of section 6(j) of the Export Administration Act of 1979, to haverepeatedly provided support for acts of international terrorism; and

(3) poses no significant threat to United States national security, interests, or allies.

The ISA is structured a little funny – the reporting requirements (Section 4) being enumerated earlier than the actual description of sanctions and whom they're applicable to (Sections 5 and 6). Subsequent posts will cover the remainder of the Act, even though some of this was covered in an earlier post on what the ISA sanctions actually were.

Next up: when will sanctions be applied?

Link:

Iran Sanctions Act of 1996

 

Regulatory Spotlight: ISA Sanctions

Since Mr. Watchlist has noticed references to the ISA (Iran Sanctions Act of 1996) sanctions as he's been documenting the details of IFCA (Iran Freedom and Counterproliferation Act), he thought it might be good to list the sanctions that the President can imposed under ISA.

The sanctions that can be imposed are:

  • The Export-Import Bank can be barred from assisting (e.g. loan guarantees, insurance, credit) exports to the sanctioned person or entity
  • Exports to the sanctioned person under federal programs which require prior approval (including Export Administration Act of 1979, Arms Export Control Act, and the Atomic Energy Act of 1954) can be prohibited
  • US financial institutions can be barred from giving loans or other credit in excess of $10 million per year to sanctioned persons unless the loan is to “relieve human suffering”
  • Sanctioned financial institutions can be barred from being a primary dealer in US government securities
  • Sanctioned financial institutions can be barred from holding US government funds
  • The US government can be prohibited from procuring goods and services from a sanctioned person
  • Foreign exchange deals that a sanctioned person has an interest in, and which the US has jurisdiction over (i.e. one of the currencies is the US dollar, or involving US financial institutions or foreign financial institutions' US branches) can be banned
  • Payments between financial institutions that a sanctioned person has an interest in, and which the US has jurisdiction over (i.e. in US dollars or involving US financial institutions or foreign financial institutions' US branches) can be prohibited
  • Dealing in any property that a sanctioned person has an interest – the actual wordings are “acquiring, holding, withholding, using, transferring, withdrawing, transporting, importing, or exporting”, “dealing in or exercising any right, power, or privilege with respect to such property” and “conducting any transaction involving such property.”
  • Restrictions on imports involving a sanctioned person can be imposed as per IEEPA (International Emergency Economic Powers Act) – this one's written much more vaguely than the others (it's entitled “additional sanctions”)

There's another section in the ISA right after this one that's also kind of interesting. Prospective contractors with the US government have to certify that they don't engage in the activities that can get them sanctioned (technically, this became true only within 90 days after CISADA became law). If you lie about it, you can be put on a list of parties excluded from federal procurement programs (and nonprocurement programs, which include things like loans, guarantees and scholarships – in other words, funds from the government which are not in return for goods or services).

OFAC Update: 3 names removed from ISA sanctions

This afternoon, OFAC removed the following names from the ISA sanctions list:

 

Allvale Maritime Inc., 80 Broad Street, Monrovia, Liberia

 

Société Anonyme Monégasque D’Administration Maritime Et Aérienne (a.k.a. S.A.M.A.M.A., a.k.a. SAMAMA), Villa Saint Jean, 3 Ruelle Saint Jean, MC 98000, Monaco

 

Tanker Pacific Management (Singapore) Pte Ltd, 1 Temasek Avenue, #38-01,Millenia Tower, Singapore 039192

Under ISA, US financial institutions may not provide loans or other credit in excess of $10 million in a 12-month period to sanctioned entities, other than to fund activities that alleviate “human suffering.”

It appears that, with these removals, there are only 3 remaining entities sanctioned under ISA, which sanctions entities which have had involvement with Iran's energy and/or refined petroleum industries.

 

Links:

OFAC News Release

ISA Sanctions Flyer