Since the 1-year designation period was almost up, Her Majesty’s Treasury on Wednesday renewed the designation for the Basque separatist group ETA:
BASQUE FATHERLAND AND LIBERTY a.k.a: (1) ETA
(2) Euzkadi Ta Askatasuna Other Information: UK listing only. Group ID: 7083.
Links:
On Wednesday, OSFI made the changes to its Consolidated list that DFAT made earlier in the week, including deleting Osama bin Laden’s record. In addition, they also instituted the following addition to the terror rolls from the UN:
TI.N.166.13. Name: 1: AHMED SHAH 2: NOORZAI 3: OBAIDULLAH 4: na
Name (original script): احمد شاه نورزی عبیدالله
Title: Mullah Designation: na DOB: a) 1 Jan. 1985 b) 1981 POB: Quetta, Pakistan Good quality a.k.a.: a) Mullah Ahmed Shah Noorzai b) Haji Ahmad Shah c) Haji Mullah Ahmad Shah d) Maulawi Ahmed Shah e) Mullah Mohammed Shah Low quality a.k.a.: na Nationality: na Passport no.: Pakistani passport number NC5140251, issued on 23 Oct. 2009 expires on 22 October 2014 National identification no.: Pakistani national identity card number 54401-2288025-9 Address: Quetta, Pakistan Listed on: 26 Feb. 2013 Other information: Owns and operates the Roshan Money Exchange (TE.R.11.12.). Provided financial services to Ghul Agha Ishakzai (TI.I.147.10.) and other Taliban in Helmand Province. Alternative title is Maulavi.
Links:
OSFI Notice
UN Notice regarding Ahmed Shah Noorzai Obaidullah
On Tuesday, OFAC added a Mali national, 2 Pakistani nationals and a terror group out of Pakistan to the SDN list:
GHALI, Iyad ag (a.k.a. GHALY, Iyad ag); DOB 1954; POB Abeibara, Kidal Region, Mali; nationality Mali (individual) [SDGT].
NOORZAI, Mullah Ahmed Shah (a.k.a. SHAH, Haji Ahmad; a.k.a. SHAH, Haji Mullah Ahmad; a.k.a. SHAH, Maulawi Ahmed; a.k.a. SHAH, Mullah Mohammed), Quetta, Pakistan; DOB 01 Jan 1985; alt. DOB 1981; POB Quetta, Pakistan; Passport NC5140251 (Pakistan) issued 23 Oct 2009 expires 22 Oct 2014; National ID No. 5440122880259 (Pakistan) (individual) [SDGT].
WAZIR, Malang (a.k.a. JAN, Malang; a.k.a. MOHAMMED, Wali), Wana, South Waziristan, Pakistan; DOB 1975 (individual) [SDGT].
…
COMMANDER NAZIR GROUP (a.k.a. MULLAH NAZIR GROUP), South Waziristan, Pakistan; Paktika, Zabul, Helmand, Kandahar Provinces, Afghanistan [SDGT].
Links:
DFAT has added the following individual to its Consolidated List, based on the update from the UN under Resolution 2083 (2012):
QI.A.316.13. Name: 1: IYAD 2: AG GHALI 3: na 4: na
Title: na Designation: na DOB: 1954 POB: Abeibara, Kidal region, Mali Good quality a.k.a.: na Low quality a.k.a.: na Nationality: Malian Passport no.: na National identification no.: na Address: Mali Listed on: 25 Feb. 2013 Other information: Founder and leader of Ansar Eddine. Member of the Tuareg Ifogas tribe. Linked to the Organization of Al-Qaida in the Islamic Maghreb (QE.T.14.01) and Mouvement pour l’Unification et le Jihad en Afrique de l’Ouest (MUJAO) (QE.M.134.12).
Links:
Not as earth-shattering as the removal of Osama bin Laden, of course…
QI.O.314.13. Name: 1: ABDERRAHMANE 2: OULD EL AMAR 3: na 4: na
Title: na Designation: na DOB: 1977 -1982 POB: Tabankort, Mali Good quality a.k.a.: a) Ahmed el Tilemsi b) Abderrahmane Ould el Amar Ould Sidahmed Loukbeiti c) Ahmad Ould Amar Low quality a.k.a.: na Nationality: Malian Passport no.: na National identification no.: na Address: a) Gao, Mali b) Tabankort, Mali c) In Khalil, Mali d) Al Moustarat, Mali Listed on: 22 Feb. 2013 Other information: Leader of the Mouvement pour l’Unification et le Jihad en Afrique de l’Ouest (MUJAO) (QE.M.134.12.). Member of The Organization of Al- Qaida in the Islamic Maghreb (QE.T.14.01.). Arrested in April 2005 in Mauritania, escaped from Nouakchott jail on 26 Apr. 2006. Re-arrested in Sep. 2008 in Mali and released on 15 Apr. 2009. Associated with Mokhtar Belmokhtar (QI.B.136.03). Father’s name is Leewemere.QI.O.315.13. Name: 1: HAMADA 2: OULD MOHAMED EL KHAIRY 3: na 4: na
Title: na Designation: na DOB: 1970 POB: Nouakchott, Mauritania Good quality a.k.a.: a)
Hamad el Khairy b) Hamada Ould Mohamed Lemine Ould Mohamed el Khairy c) Ould Kheirou Low quality a.k.a.: Abou QumQum Nationality: a) Mauritanian b) Malian Passport no.: Malian passport number A1447120, expired on 19 Oct. 2011 National identification no.: na Address: Gao, Mali Listed on: 22 Feb. 2013 Other information: Leader of the Mouvement pour l’Unification et le Jihad en Afrique de l’Ouest (MUJAO) (QE.M.134.12.). Has provided logistical support to the Sahelian group Al Moulathamine, linked with the Organization of Al-Qaida in the Islamic Maghreb (QE.T.14.01). International arrest warrant issued by Mauritania. Mother’s name is Tijal Bint Mohamed Dadda.
Links:
Monday, Australia’s DFAT made updates to its Consolidated List based on recommendations by UN committees on Al Qaida (pursuant to resolutions 1267 and 1989). Nothing unusual there – until you see who the UN removed from its list:
QI.B.8.01. Name: 1: USAMA 2: MUHAMMED 3: AWAD 4: BIN LADEN
Title: a) Shaykh b) Hajj Designation: na DOB: a) 30 Jul. 1957 b) 28 Jul. 1957 c) 10 Mar. 1957 d) 1 Jan. 1957 e) 1956 f) 1957 POB: a) Jeddah, Saudi Arabia b)
Yemen Good quality a.k.a.: a) Usama Bin Laden b) Usama Bin Muhammed Bin Awad, Osama Bin Laden c) Ben Laden Osama d) Ben Laden Ossama e) Ben Laden Usama f) Bin Laden Osama Mohamed Awdh g) Bin Laden Usamah Bin Muhammad h) Shaykh Usama Bin Ladin i) Usamah Bin Muhammad Bin Ladin j) Usama bin Ladin k) Osama bin Ladin l) Osama bin Muhammad bin Awad bin Ladin m) Usama bin Muhammad bin Awad bin Ladin Low quality a.k.a.: a) Abu Abdallah Abd Al-Hakim b) Al Qaqa Nationality: na Passport no.: na National identification no.: na Address: na Listed on: 25 Jan. 2001 (amended on 2 Jul. 2007, 16 Dec. 2010, 4 May
2011) Other information: Saudi citizenship withdrawn, Afghan nationality given by the Taliban regime. Review pursuant to Security Council resolution 1822 (2008) was concluded on 21 Jun. 2010. Confirmed to have died in Pakistan in May 2011.
Outside the US, sanctions are treated like law enforcement: when the bad guy dies, he or she is no longer of interest, so the person can be removed from the list.
OFAC knows better: dead men may not tell tales, but they can leave behind assets in their names that their associates can lay their hands on. So, Osama bin Laden is not leaving the SDN list any time soon – nor is Saddam Hussein, or Abu Musab al-Zarqawi, etc.
A separate post follows next on the other DFAT/UN changes.
Bank of Guam made a $2625 wire transfer to the UAE to settle delivery fees of goods shipped to Iran. A US bank blocked the transfer because Iran was mentioned in the originator to beneficiary information of the payment. A couple of weeks later, the same payment was resent (successfully) with the Iran reference removed on the guidance of a Bank employee.
The base fine was $20,000, yet the final fine was $27,000. Why?
The settlement amount reflects OFAC’s consideration of the following facts and circumstances, pursuant to the General Factors under OFAC’s Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A: although mitigation was extended because Bank of Guam has not received a penalty notice or a Finding of Violation from OFAC in the five years preceding the date of the transactions giving rise to the apparent violations, the settlement amount reflects an aggravation to the base penalty because Bank of Guam staff acted recklessly by failing to exercise caution or care in processing a funds transfer after becoming aware of the purpose of the payment and actually instructed the bank’s customer to resubmit the payment without a reference to Iran in the payment details thereby concealing the sanctioned interest in the transaction. Such conduct undermined the integrity of the U.S. sanctions program, prevented Bank of Guam’s correspondent from assessing the permissibility of the payment, and could have resulted in significant sanctions harm. At the time, Bank of Guam employees apparently lacked an understanding of the bank’s U.S. sanctions obligations.
Interesting note: At the time of the violation, the relevant regulation was called the Iranian Transactions Regulations (ITR). A footnote in the OFAC notice notes that the ITR has since been renamed and reissued, in its entirety, as the Iranian Transactions and Sanctions Regulations (ITSR) in October of last year.
Link: