Quantcast
Channel: Mr. Watchlist
Viewing all 8457 articles
Browse latest View live

HK SFC AML/CTF Circular: FATF statements

$
0
0

Circular to Licensed Corporations and Associated Entities 

Anti-Money Laundering / Counter-Financing of Terrorism 

(1)  FATF Statement on Democratic People’s Republic of Korea and Iran

(2)  FATF Statement on Improving Global AML/CFT Compliance: On-Going Process

(3)  Outcomes from the Meeting of the FATF Plenary, 20-22 February 2019

(1)  FATF Statement on Democratic People’s Republic of Korea and Iran

Further to our circular issued on 29 October 2018, this is to inform you that the Financial Action Task Force (“FATF”) issued an updated statement on 22 February 2019 identifying jurisdictions that have strategic deficiencies in their anti-money laundering and combating the financing of terrorism (“AML/CFT”) regimes.

The statement Note 1 has been separated into two sections.

(i)   Jurisdiction subject to a call on its members and other jurisdictions to apply counter-measures

Democratic People’s Republic of Korea (“DPRK”)

The FATF remains concerned by the DPRK’s failure to address the significant deficiencies in its AML/CFT regime and the serious threat this poses to the integrity of the international financial system.  Further, the FATF has serious concerns with the threat posed by the DPRK’s illicit activities related to the proliferation of weapons of mass destruction (“WMDs”) and its financing.  The FATF calls on its members and other jurisdictions to continue to apply counter-measures and targeted financial sanctions in accordance with applicable United Nations Security Council (“UNSC”) Resolutions to protect the international financial system from the on-going and substantial money laundering, terrorist financing and WMD proliferation financing risks emanating from the jurisdiction.

Licensed corporations (“LCs”) and associated entities (“AEs”) should give special attention to business relationships and transactions with the DPRK, including DPRK companies, financial institutions and those acting on their behalf, and subject them to increased scrutiny and enhanced due diligence measures.

In addition, LCs and AEs are reminded that it is an offence under section 4 of the Weapons of Mass Destruction (Control of Provision of Services) Ordinance (Cap. 526) for a person to provide any services where he believes or suspects, on reasonable grounds, that those services may be connected to WMD proliferation.

(ii)    Jurisdiction subject to a call on its members and other jurisdictions to apply enhanced due diligence measures proportionate to the risks arising from the jurisdiction 

Iran

In June 2016, the FATF welcomed Iran’s adoption of an action plan to address its strategic AML/CFT deficiencies and suspended counter-measures accordingly. In November 2017, Iran established a cash declaration regime. In August 2018, Iran has enacted amendments to its Counter-Terrorist Financing Act and in January 2019, Iran has also enacted amendments to its Anti-Money Laundering Act. The bills (which are not yet in force) to ratify the Palermo and Terrorist Financing Conventions have passed the Parliament. However, Iran’s action plan has expired with a number of items remains outstanding.

The FATF decided in the recent Plenary Meeting to continue the suspension of counter-measures noting the progress of the legislative efforts of Iran. While welcoming the passage of the Anti-Money Laundering Act, the FATF expresses its disappointment that the action plan to address Iran’s strategic AML/CFT deficiencies remains outstanding and expects Iran to proceed swiftly in the reform path to ensure that it addresses all of the remaining items by completing and implementing the necessary AML/CFT reforms. If by June 2019, Iran does not enact the remaining legislation in line with FATF standards, then the FATF will require increased supervisory examination for branches and subsidiaries of financial institutions based in Iran.

Until Iran fully implements the measures required to address the deficiencies identified with respect to countering financing of terrorism in the action plan, the FATF remains concerned with the risk of terrorist financing emanating from Iran and the threat this poses to the international financial system.  The FATF calls on its members and other jurisdictions to continue to apply enhanced due diligence measures proportionate to the risks arising from the jurisdiction.

LCs and AEs should apply enhanced due diligence measures, including obtaining information on the reasons for intended transactions, and conducting enhanced monitoring of business relationships, by increasing the number and timing of controls applied, and selecting patterns of transactions that need further examination, to business relationships and transactions with natural and legal persons from Iran. LCs and AEs are further advised that the type of enhanced due diligence measures applied should be effective and proportionate to the risks, and in line with the standards as specified in the FATF statement Note 1.

(2)  FATF Statement on Improving Global AML/CFT Compliance: On-Going Process

In addition, please be informed that as part of the on-going process to improve global AML/CFT compliance, the FATF has set out in a separate statement an updated list of jurisdictions that have strategic AML/CFT deficiencies for which they have developed an action plan with the FATF.  The FATF will closely monitor the implementation of those action plans and encourage its members to consider the information presented in the statement which can be found on the website of the FATF (http://www.fatf-gafi.org/publications/high-riskandnon-cooperativejurisdictions/documents/fatf-compliance-february-2019.html).

As the FATF will continue to assess the progress made by these jurisdictions in addressing the deficiencies in their AML/CFT systems and issue updated statements from time to time, LCs and AEs are reminded to browse the website of the FATF for the latest information.

(3)  Outcomes from the Meeting of the FATF Plenary, 20-22 February 2019 

In addition to the statements in (1) and (2) above, the FATF has also published various other outcomes of its recent Plenary Meeting which may be of interest to LCs and AEs. They include, for example, (i) FATF’s current action to combat terrorist financing, and (ii) Interpretive Note to FATF Recommendation 15 for mitigating risks from virtual assets. Further information can be found on the website of FATF (http://www.fatf-gafi.org/publications/fatfgeneral/documents/outcomes-plenary-february-2019.html).

Should you have any queries regarding the contents of this circular, please contact Ms Kiki Wong at 2231 1569 who will assist to refer your queries to the relevant officer.

Intermediaries Supervision Department
Intermediaries Division
Securities and Futures Commission

End

SFO/IS/007/2019

Links:

HK SFC Notice

HK SFC Circular


March 25, 2019: OFAC updates Syria Shipping Advisory

$
0
0

On Monday, OFAC issued an updated version of its November advisory to the maritime shipping industry that highlighted risks of shipments made to Syria. And the Treasury Department issued the following press release:

Updated Treasury Advisory Highlights Risks for Maritime Petroleum Shipping Community in Syria

Dozens of new vessels involved in illicit oil shipments added

WASHINGTON – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated its Advisory to the Maritime Petroleum Shipping Community to highlight risks associated with shipments to Syria.  This advisory updates Treasury’s November 20, 2018 Advisory to include additional guidelines and risks associated with facilitating the shipment of petroleum destined for Syrian Government-owned and operated ports, to include petroleum of Iranian origin.  It adds dozens of new vessels involved in illicit oil shipments, including 16 shipping to Syria and more than 30 engaging in ship-to-ship transfers, and highlights concerns with shipments of petroleum from Iran.

“Treasury has previously exposed a far-reaching oil for terror network involving Iran and Syria, and continues to target ships and companies facilitating illicit trade.  The United States has made it clear to the maritime shipping community that we will not tolerate the use of petroleum as a mechanism to finance rogue regimes in Iran and Syria.  As Iran and Syria attempt to adapt their illicit tactics and shift to new vessels, we will continue to provide these updates to the shipping community,” said Under Secretary for Terrorism and Financial Intelligence, Sigal Mandelker.  “Shipping companies, insurers, vessel owners, managers, and operators must aggressively counter the ongoing deceptive shipping practices deployed by Iran and Syria and other questionable jurisdictions.  Any violations of prohibitions or weaknesses in compliance that result in sanctionable conduct exposes the shipping community to significant risks and can trigger severe consequences.”

The new iteration of the Advisory includes major updates to its annex, which lists vessels that have delivered petroleum to Syria since 2016.  The annex also includes vessels that have engaged in ship-to-ship (STS) transfers of petroleum likely destined for Syria, as well as vessels which have exported Syrian petroleum.  Many of the names of the vessels have also been updated to reflect name changes.

A link to the updated Advisory (as well as to the North Korea one updated last week) appears on the Guidance and Resources page.

Links:

OFAC Notice

Updated Syria Shipping Advisory

Treasury Press Release

UN, OSFI, DFAT add Tariq Gidar Group to counter terror sanctions

$
0
0

Today, Canadian and Australian regulators added the following entity:

QDe.160 Name: TARIQ GIDAR GROUP (TGG)
Name (original script): طارق گیدڑ گروپ
A.k.a.: a) TEHRIK-E-TALIBAN-TARIQ GIDAR GROUP b) TTP-TARIQ GIDAR GROUP c) TEHREEK-I-TALIBAN PAKISTAN GEEDAR GROUP d) TTP GEEDAR GROUP e) TARIQ GEEDAR GROUP f) COMMANDER TARIQ AFRIDI GROUPg) TARIQ AFRIDI GROUP h) TARIQ GIDAR AFRIDI GROUP i) THE ASIAN TIGERS F.k.a.: na Address: (Afghanistan/Pakistan border region) Listed on: 22 Mar. 2019 Other information: Splinter group of Tehrik-e Taliban Pakistan (TTP) (QDe.132). The group was formed in Darra Adam Khel, Federally Administered Tribal Area (FATA), Pakistan, in 2007.  INTERPOL-UN Security Council Special Notice web link:  www.interpol.int/en/notice/search/une/xxxx.

to their counter terrorism sanctions, after its addition by the United Nations ISIL (Da’esh) and Al-Qaida Sanctions Committee.

Links:

OSFI Notice

UN Notices – PDF (DFAT), HTML (OSFI)

Another major round of OFAC Iran designations

$
0
0

Today, OFAC added the following people:

ALE ALI, Mohammad Reza; POB Shemiran, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 0451519639 (Iran) (individual) [SDGT] [IFSR] (Linked To: ANSAR EXCHANGE). 

 

ATABAKI, Alireza; DOB 1961; POB Tehran Province, Central Tehran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 0042773296 (Iran) (individual) [SDGT] [IRGC] [IFSR] (Linked To: ANSAR EXCHANGE). 

 

DASTGIRI, Reza Sakan; POB West Azerbaijan, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 2830283775 (Iran) (individual) [SDGT] [IFSR] (Linked To: SAKAN GENERAL TRADING). 

 

EBRAHIMI, Ayatollah; DOB 1972; POB Qomshaneh, Hamadan Province, Iran; Additional Sanctions Information – Subject to Secondary Sanctions (individual) [SDGT] [IRGC] [IFSR] (Linked To: ANSAR BANK). 

 

GALESHKALAMI, Iman Sedaghat; POB Gilan, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 2709803755 (Iran) (individual) [SDGT] [IFSR] (Linked To: ZAGROS PARDIS KISH; Linked To: MINISTRY OF DEFENSE AND ARMED FORCES LOGISTICS). 

 

MULAVI, Ali Shams (a.k.a. MOULAVI, Ali Shams), Turkey; DOB 23 Jul 1980; Additional Sanctions Information – Subject to Secondary Sanctions; Passport I95726252 (Iran) (individual) [SDGT] [IFSR] (Linked To: ANSAR EXCHANGE). 

 

SAKAN, Suleyman, Turkey; DOB 25 Sep 1965; Additional Sanctions Information – Subject to Secondary Sanctions; Passport U06595028 (Turkey) (individual) [SDGT] [IFSR] (Linked To: ANSAR EXCHANGE). 

 

SEIFI, Asadollah (a.k.a. SEIFY, Asadollah; a.k.a. SEYFI, Esdaleh); DOB 04 Apr 1965; Additional Sanctions Information – Subject to Secondary Sanctions (individual) [SDGT] [IFSR] (Linked To: ATLAS EXCHANGE). 

 

VAKILI, Mohammad, United Arab Emirates; DOB 22 Jun 1974; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 0082676984 (Iran); Birth Certificate Number 9444 (Iran) (individual) [SDGT] [IFSR] (Linked To: ATABAKI, Alireza).

and entities:

ANSAR BANK BROKERAGE COMPANY (f.k.a. PAR GOSTAR KHOBREH), Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Business Registration Number 24467 (Iran) [SDGT] [IRGC] [IFSR] (Linked To: ANSAR BANK). 

 

ANSAR EXCHANGE (a.k.a. SARAFI ANSAR; a.k.a. SARAFI ANSAR COMPANY), No. 41, Joibar Street, Fatemi Square, Tehran, Iran; Website Ansarexchange.ir; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 10320743975 (Iran); Business Registration Number 423264 (Iran) [SDGT] [IRGC] [IFSR] (Linked To: ANSAR BANK; Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE; Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 

 

ANSAR INFORMATION TECHNOLOGY COMPANY (f.k.a. FANAVARAN HAFIZEH SAMANEH), No. 59, West Taban Street, Jordon (Nelson Mandela) Street, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Business Registration Number 190617 (Iran) [SDGT] [IRGC] [IFSR] (Linked To: ANSAR BANK). 

 

ATLAS DOVIZ TICARETI A.S. (a.k.a. ATLAS DOVIZ), Tayahatun Mah., Tclar Sok. No: 83, Mercan Kaps-Kapal Car, Eminonu, Istanbul, Turkey; Website http://www.atlasdoviz.com; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: SAKAN, Suleyman). 

 

ATLAS EXCHANGE (a.k.a. ATLAS CURRENCY EXCHANGE; a.k.a. TAZAMONI VAKILI AND PARTNERS; a.k.a. VAKILI JOINT PARTNERSHIP), No. 77, Commercial Center Market (Bazar Markazi Tejari), Ferdosi Street, Kish Island, Iran; Website http://www.atlassarafi.com; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: ANSAR EXCHANGE). 

 

GOLDEN COMMODITIES LLC, 1805, Al Owais Tower, Baniyas Road, Deira, Dubai, United Arab Emirates; P.O. Box 31662, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: SEIFI, Asadollah). 

 

HITAL EXCHANGE (a.k.a. SARAFI SEYYED MOHAMMAD REZA ALE ALI AND PARTNERS; a.k.a. SEYYED MOHAMMAD REZA ALE ALI CURRENCY EXCHANGE), No. 2486, Tolu Shopping Center, Vali Asr Street, Tavanir Street, Tehran 1434853851, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 14005467510 (Iran); Registration Number 483939 (Iran) [SDGT] [IFSR] (Linked To: ALE ALI, Mohammad Reza). 

 

IRANIAN ATLAS COMPANY, No. 5, 10th Baharestan, Pasdaran Street, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Business Registration Number 59784 (Iran) [SDGT] [IRGC] [IFSR] (Linked To: ANSAR BANK). 

 

LEBRA MOON GENERAL TRADING LLC, Office 503, Centurion Star Building B, Al Etihad Road, Port Saeed, Dubai, United Arab Emirates; P.O. 185331, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions; License 735469 (United Arab Emirates) [SDGT] [IFSR] (Linked To: MINISTRY OF DEFENSE AND ARMED FORCES LOGISTICS; Linked To: ANSAR EXCHANGE). 

 

NARIA GENERAL TRADING LLC, Office 503, Centurion Star Building B, Al Etihad Road, Port Saeed, Dubai, United Arab Emirates; P.O. Box 185331, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions; License 751444 (United Arab Emirates) [SDGT] [IFSR] (Linked To: ANSAR EXCHANGE). 

 

SAKAN EXCHANGE (a.k.a. JOINT PARTNERSHIP OF REZA SAKAN DASTGIRI AND ASSOCIATES; a.k.a. TAZAMONI REZA SAKAN DASTGIRI VA SHORAK), No. 22, First Floor, Islaelzadeh Building, Shahid Javad Ghanbari Street, Bazargan, Maku Free Trade Zone, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 14003282053 (Iran) [SDGT] [IFSR] (Linked To: DASTGIRI, Reza Sakan). 

 

SAKAN GENERAL TRADING (a.k.a. ROYAL CREDIT GENERAL TRADING; a.k.a. SAKAN GENERAL TRADING, LLC), 14th Floor, Office 1401, Al Owais Business Tower, 53, 24th Street, Al Sabkha-115, Deira, Dubai, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions; License 611462 (United Arab Emirates) [SDGT] [IFSR] (Linked To: ANSAR EXCHANGE). 

 

THE BEST LEADER GENERAL TRADING LLC (a.k.a. WILMINGTON GENERAL TRADING LLC), 1805, Al Owais Tower, Binias Road, Deira, Dubai, United Arab Emirates; P.O. 31622, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions; License 668722 (United Arab Emirates) [SDGT] [IFSR] (Linked To: SEIFI, Asadollah). 

 

ZAGROS PARDIS KISH, No. 192, Pardis 1 Market, Kish Island 794188338, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 10980205334 (Iran); Business Registration Number 8953 (Iran) [SDGT] [IRGC] [IFSR] (Linked To: MINISTRY OF DEFENSE AND ARMED FORCES LOGISTICS; Linked To: ATABAKI, Alireza). 

 

to its Iran and counter terrorism sanctions programs.

Additionally, the following 2 listings were updated:

ANSAR BANK (a.k.a. ANSAR FINANCE AND CREDIT FUND; a.k.a. ANSAR FINANCIAL AND CREDIT INSTITUTE; a.k.a. BANK-E ANSAR; f.k.a. “ANSAR AL-MOJAHEDIN NO-INTEREST LOAN INSTITUTE”; f.k.a. “ANSAR INSTITUTE”; f.k.a. “ANSAR SAVING AND INTEREST FREE-LOANS FUND”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran; North Pasdaran St., No. 539, Before Sahebgharanieh, corner of Narenjestan dahom, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN] [NPWMD] [IFSR]. -to- ANSAR BANK (a.k.a. ANSAR FINANCE AND CREDIT FUND; a.k.a. ANSAR FINANCIAL AND CREDIT INSTITUTE; a.k.a. BANK ANSAR; a.k.a. BANK-E ANSAR; f.k.a. “ANSAR AL-MOJAHEDIN NO-INTEREST LOAN INSTITUTE”; f.k.a. “ANSAR INSTITUTE”; f.k.a. “ANSAR SAVING AND INTEREST FREE-LOANS FUND”), Building No. 539, North Pasdaran Street, Tehran 19575-497, Iran; Website http://www.ansarbank.com; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN] [SDGT] [NPWMD] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE; Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 

 

MINISTRY OF DEFENSE FOR ARMED FORCES LOGISTICS (a.k.a. MINISTRY OF DEFENSE AND SUPPORT FOR ARMED FORCES LOGISTICS; a.k.a. MODAFL; a.k.a. MODSAF), located on the west side of Dabestan Street, Abbas Abad District, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR]. -to- MINISTRY OF DEFENSE AND ARMED FORCES LOGISTICS (a.k.a. GOVERNMENT OF IRAN DEPARTMENT OF DEFENSE; a.k.a. MINISTRY OF DEFENCE & ARMED FORCES LOGISTICS; a.k.a. MINISTRY OF DEFENSE AND SUPPORT FOR ARMED FORCES LOGISTICS; a.k.a. MINISTRY OF DEFENSE ARMED FORCES LOGISTICS; a.k.a. MINISTRY OF DEFENSE FOR ARMED FORCES LOGISTICS; a.k.a. MODAFL; a.k.a. MODSAF; a.k.a. VEZARATE DEFA; a.k.a. VEZARAT-E DEFA VA POSHTYBANI-E NIRU-HAYE MOSALLAH), Ferdowsi Avenue, Sarhang Sakhaei Street, Tehran, Iran; PO Box 11365-8439, Pasdaran Ave., Tehran, Iran; West side of Dabestan Street, Abbas Abad District, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [NPWMD] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE).  

And Treasury issued the following press release:

United States Disrupts Large Scale Front Company Network Transferring Hundreds of Millions of Dollars and Euros to the IRGC and Iran’s Ministry of Defense

WASHINGTON – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action against 25 individuals and entities, including a network of Iran, UAE, and Turkey-based front companies, that have transferred over a billion dollars and euros to the Islamic Revolutionary Guard Corps (IRGC) and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL), in addition to procuring millions of dollars’ worth of vehicles for MODAFL.  Today’s action exposes an extensive sanctions evasion network established by the Iranian regime, which it increasingly relies on as the United States’ maximum pressure campaign severely constricts the regime’s sources of revenue.  OFAC also designated Iran’s MODAFL pursuant to Executive Order (E.O.) 13224 for its role in assisting the IRGC-Qods Force (IRGC-QF), as well as an Iran-based bank for providing banking services to the IRGC-QF.

“We are targeting a vast network of front companies and individuals located in Iran, Turkey, and the UAE to disrupt a scheme the Iranian regime has used to illicitly move more than a billion dollars in funds,” said Treasury Secretary Steven T. Mnuchin.  “The IRGC, MODAFL, and other malign actors in Iran continue to exploit the international financial system to evade sanctions, while the regime funds terrorism and other destabilizing activities across the region.”  

“Central to this network and sanctioned today pursuant to our counterterrorism authority is Iran’s IRGC-controlled Ansar Bank and its currency exchange arm, Ansar Exchange, both of which used layers of intermediary entities to exchange devalued Iranian rial ultimately for dollars and euros to line the pockets of the IRGC and MODAFL.  This vast network is just the latest example of the Iranian regime’s use of deceptive practices to exploit the global financial system and divert resources to sanctioned entities,” said Treasury Under Secretary for Terrorism and Financial Intelligence Sigal Mandelker.  “This once again exposes to the international community the dangerous risks of operating in an Iranian economy that is deliberately opaque.”

ANSAR BANK’S SANCTIONS EVASION SCHEME

Through IRGC-controlled Ansar Bank, the Iranian regime established a layered network of front companies based in Iran, Turkey, and the UAE to bypass sanctions, gain access to the international financial system, and exchange devalued Iranian rial for dollars and euros. Ansar Bank also used international free zones to establish front companies. 

As part of this scheme, Ansar Bank used its Iran-based foreign currency arm, Ansar Exchange and its network, to convert Iranian rial ultimately to hundreds of millions of dollars and euros.  To provide this funding to Ansar Bank, MODAFL, and the IRGC, Ansar Exchange relied upon a network of front companies and agents in Turkey and the UAE.  In just the last year-and-a-half, four front companies- UAE-based Sakan General Trading, Lebra Moon General Trading, and Naria General Trading, as well as Iran-based Hital Exchange,  all designated today — provided the equivalent of approximately $800 million in funds to Ansar Exchange.  Additionally, Turkey-based Atlas Doviz acted as a secondary foreign currency provider for Ansar Exchange.  

These front companies are witting to Iran’s sanctions evasion. For example, as of 2019, Ansar Exchange Managing Director Alierza Atabaki worked closely with one central procurement agent, Reza Sakan, to avoid the scrutiny of Emirati authorities regarding Ansar Exchange’s financial dealings with UAE-based Sakan General Trading and other identified Ansar Exchange intermediaries.

Ansar Exchange network image

View the chart in Farsi describing Ansar Bank’s sanctions evasion scheme.

MODAFL, ANSAR BANK, AND ITS IRAN-BASED SUBSIDIARIES

MODAFL

MODAFL, first designated in 2007 pursuant to E.O. 13382 for supporting persons involved in Iran’s proliferation activities, supervises Iran’s development and production of missiles, including those used by Iran-backed Houthi militias in Yemen against coalition forces.  Today, OFAC designated MODAFL for providing logistic support to the IRGC-QF and its regional proxy groups.  Specifically, MODAFL was designated pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC-QF.

As of 2017, MODAFL used funds from the Central Bank of Iran (CBI) that were earmarked for the IRGC-QF.

 As a part of this scheme, multiple UAE-based firms were involved in the acquisition of hundreds of vehicles by MODAFL, an endeavor that also involved Iran-based Zagros Pardis Kish and Reza Heidari, who was designated pursuant to E.O. 13224 on November 20, 2017 for acting for or on behalf of, and for providing support to, the IRGC-QF as a part of a large-scale IRGC-QF counterfeiting ring.  Payment for these vehicles was made to Lebra Moon General Trading. Naria General Trading was also involved in the vehicle acquisition.

Ansar Bank and Ayatollah Ebrahimi

IRGC-controlled Ansar Bank was previously designated pursuant to E.O. 13382 in 2010. Today, OFAC designated Ansar Bank pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC-QF, and for being owned or controlled by the IRGC. With 1,081 branches throughout Iran, Ansar Bank procured hundreds of millions of dollars in the last three years on the IRGC’s behalf.

As recently as 2019, Ansar Bank officials maintained close associations with senior IRGC-QF officials and financial facilitators who use accounts at Ansar Bank to keep the equivalent of millions of dollars. For example, Treasury-designated IRGC-QF financial facilitator Meghdad Amini held funds at Ansar Bank.

Ansar Bank also extended the equivalent of millions of dollars as a loan to an IRGC-QF front company. IRGC-QF officials’ salaries also have been paid using Ansar Bank, and Ansar Bank is used by the IRGC-QF to pay the salaries of its foreign fighters, particularly those based in Syria. On October 16, 2018, Treasury designated two of these Syria-based, IRGC-QF-backed militias, the Fatemiyoun Division and Zainabiyoun Brigade, which are comprised of foreign fighters, including child soldiers as young as 14 years old.  

Ayatollah Ebrahimi, who was recruited into the IRGC at the age of 14, has been the managing director of Ansar Bank since 2005. In this capacity, Ebrahimi worked directly with IRGC-QF officials to facilitate their financial activities, including the conversion of euros or the UAE dirham for the terrorist group. Ayatollah Ebrahimi is being designated pursuant to E.O. 13224 for acting for or on behalf of Ansar Bank.

Treasury is also taking action against a number of Iranian firms owned, or under the control of, Ansar Bank. Specifically, Iranian Atlas Company, Ansar Bank Brokerage Company, and Ansar Information Technology are being designated pursuant to E.O. 13224 for being owned or controlled by Ansar Bank.

ANSAR EXCHANGE AND ITS NETWORK OF PROCUREMENT AGENTS

Ansar Exchange

Central to this foreign currency procurement network is Iran-based Ansar Exchange, which conducted significant volumes of foreign currency exchange services for sanctioned Iranian entities, including Ansar Bank, MODAFL, and the IRGC. Ansar Exchange is wholly owned and controlled by Ansar Bank.

Since 2016, Ansar Exchange conducted currency exchange services for Ansar Bank totaling over one billion dollars. Over the past few years, Ansar Exchange also directly provided MODAFL with the equivalent of approximately 100 million in dollars and euros, in addition to the equivalent of approximately 130 million dollars’ worth of goods and services ultimately destined for the benefit of the IRGC.

As recently as 2019, Ansar Exchange maintained a close association with senior IRGC-QF officials.  Ansar Exchange is being designated pursuant to E.O. 13224 for being owned or controlled by Ansar Bank, and for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Ansar Bank.  Ansar Exchange is also being designated for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC-QF, and for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC.

Alireza Atabaki

Alireza Atabaki is the managing director of Ansar Exchange. He co-owns Zagros Pardis Kish with Reza Heidari, an individual designated by Treasury in 2017 for acting for or on behalf of, and providing support to, the IRGC-QF. As recently as early 2019, Atabaki has worked with the IRGC-QF and coordinated transactions using an identified IRGC-QF front company. 

Alireza Atabaki is being designated pursuant to E.O. 13224 for acting for or on behalf of Ansar

Exchange.

In 2018, Iran-based Atlas Exchange — also designated today — at the behest of Atabaki, paid hundreds of thousands of euros and dirham to companies in Europe and the UAE. In 2018 and 2019, Atabaki worked closely with UAE-based Iranian financial facilitator Reza Sakan and UAE-based Mohammad Vakili, both of whom are being designated today. Vakili is affiliated with UAE-based companies Best Leader General Trading LLC and Golden Commodities General Trading LLC. Since at least 2015, Atabaki, in coordination with Iranian financial facilitator Assadollah Seifi, used Vakili and his UAE-based companies as foreign currency procurement and financial facilitation agents to procure and transfer millions of dollars, including in cash. 

Zagros Pardis Kish

Ansar Exchange’s Managing Director Atabaki and Reza Heidari are registered as the co-owners of Zagros Pardis Kish, a company that is wholly owned by Ansar Bank. Ansar Exchange lists Zagros Pardis Kish as one of its major foreign currency customers.  

Zagros Pardis Kish was involved in MODAFL’s acquisition of hundreds of vehicles shipped from the UAE to Iran. Multiple UAE-based firms were used to pay for and ship the vehicles.  Reza Heidari and Zagros Pardis Kish manager Iman Sedaghat were involved in this endeavor. Zagros Pardis Kish is being designated pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of MODAFL, and for being owned or controlled by Alireza Atabaki.

In his capacity as manager of Zagros Pardis Kish, Iman Sedaghat coordinated the purchase of the hundreds of vehicles for MODAFL through the UAE for millions of dollars. Iman Sedaghat was previously involved in working with the IRGC-QF. Iman Sedaghat is being designated pursuant to E.O. 13224 for acting for or on behalf of Zagros Pardis Kish, and for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, MODAFL.

UAE- AND TURKEY-BASED FRONT COMPANIES

Sakan General Trading and Reza Sakan

Among the UAE-based companies sanctioned today, UAE-based Sakan General Trading provided the most foreign currency exchange support to Ansar Exchange, and is owned by UAE resident and Iranian national Reza Sakan and his Iran-based firm Sakan Exchange, also known as Joint Partnership of Reza Sakan Dastgiri and Associates. Sakan General Trading was involved in financing the purchase of military aircraft tires by Iran’s Pars Aviation Service Company for the Syrian Air Force.

Sakan General Trading recently changed its name to Royal Credit General Trading.

Sakan General Trading is being designated pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Ansar Exchange. Reza Sakan is being designated pursuant to E.O. 13224 for being otherwise associated with Sakan General Trading, as he owns or controls Sakan General Trading. Sakan Exchange is also being designated pursuant to E.O. 13224 for being owned or controlled by Reza Sakan.

Hital Exchange and Seyyed Mohammad Reza Ale Ali

Hital Exchange, also known as Seyyed Mohammad Reza Ale Ali Currency Exchange, provided a significant volume of euros and dollars to Ansar Exchange. It is owned by Iranian national Seyyed Mohammad Reza Ale Ali who worked directly with Ansar Exchange Managing Director Alireza Atabaki to convert foreign currency.

From October 2016 to March 2018, Mohammad Reza Ale Ali, using Hital Exchange, provided Ansar Exchange with the equivalent of approximately $180 million in euro and U.S. dollar banknotes. 

Today, Mohammad Reza Ale Ali is being designated pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Ansar Exchange. Hital Exchange is also being designated pursuant to E.O. 13224 for being owned or controlled by Mohammad Reza Ale Ali.

Atlas Exchange and Mohammad Vakili

Ansar Exchange also used Iran-based Atlas Exchange and its brokers to procure foreign currency.  During the latter half of 2018, Ansar Exchange directed Atlas Exchange to transfer hundreds of thousands of euros and dirham to an Iranian company in the UAE and four companies in Europe. As of early 2019, Atlas Exchange solicited business with sanctioned Iranian banks. Atlas Exchange is being designated pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Ansar Exchange.

Atlas Exchange is owned by Mohammad Vakili, who resides in the UAE and collaborated with Assadollah Seifi to use two UAE-based companies – the Best Leader General Trading and Golden Commodities General Trading – to evade sanctions. Since at least 2015, Attabaki (Ansar Exchange’s managing director) in coordination with Assadollah Seifi used Vakili and his affiliated UAE-based companies, the Best Leader General Trading and Golden Commodities, to procure and transfer millions of dollars including in cash. The Best Leader General Trading recently changed its name to Wilmington General Trading.

As recently as late 2018, Atabaki (Ansar Exchange’s managing director) coordinated closely with Mohammad Vakili on financial matters. Vakili effectuated multiple transfers worth hundreds of thousands of dollars to entities in the UAE and Turkey on behalf of Atabaki, who has instructed Vakili to increase certain deposits for companies affiliated with the scheme. Mohammad Vakili is being designated pursuant to E.O. 13224 for acting for or on behalf of Alireza Atabaki.

Asadollah Seifi, Golden Commodities General Trading, and The Best Leader General Trading

Asadollah Seifi used UAE-based Golden Commodities, which is under his supervision, and UAE-based company The Best Leader General Trading, to obfuscate millions of dollars’ worth of transactions benefiting the Iranian regime. Seifi also manages Atlas Exchange, and his procurement of U.S. dollars involved the transfer of funds through U.S.-designated banks such as Bank Mellat and Europaisch-Iranische Handelsbank AG. In August 2018, Seifi also facilitated the purchase of gold by the Iranian regime after U.S. sanctions on Iranian gold had been reimposed.

Seifi has also facilitated the purchase of foreign currency for the IRGC.

Assadolah Seifi is being designated pursuant to E.O. 13224 for acting for or on behalf of Atlas Exchange.  Golden Commodities General Trading LLC is being designated pursuant to E.O. 13224 for being owned or controlled by Asadollah Seifi. The Best Leader General Trading is being designated pursuant to E.O. 13224 for being owned or controlled by Asadollah Seifi.

Suleyman Sakan and Atlas Doviz Ticaret A.S.

Since 2017, Turkey-based Suleyman Sakan, who is affiliated with Turkish firm Atlas Doviz Ticaret A.S., provided millions of U.S. dollars in foreign currency exchange services to Ansar Exchange, including through Turkey-based Atlas Doviz. Suleyman Sakan is an associate of Reza Sakan and UAE-based Sakan General Trading. Since at least 2017, Suleyman Sakan worked with Reza Sakan to expand their business activities to Oman using the Omani financial sector.  

Suleyman Sakan is being designated pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Ansar Exchange.

Atlas Doviz Ticaret A.S. is being designated pursuant to E.O. 13224 for being owned or controlled by Suleyman Sakan.

Ali Shams Mulavi

Since 2017, another Ansar Exchange intermediary agent, Turkey-based Iranian financial facilitator Ali Shams Mulavi, has used Naria General Trading to purchase foreign currency on behalf of Ansar Exchange. In 2019, Ali Shams Mulavi procured and transferred U.S. dollar banknotes for Ansar Exchange.

Ali Shams Mulavi is being designated pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Ansar Exchange.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of these targets that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.  OFAC’s regulations generally prohibit all dealings by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated persons.

In addition, persons that engage in certain transactions with the individuals and entities designated today may themselves be exposed to sanctions or subject to an enforcement action.  Furthermore, unless an exception applies, any foreign financial institution that knowingly facilitates a significant transactions for any of the individuals or entities designated today could be subject to U.S. sanctions.

Links:

OFAC Notice

Treasury Press Release

March 26, 2019: SECO adds Tariq Gidar Group to counter terrorism sanctions

$
0
0

On Tuesday, Swiss authorities added the following entity:

SSID: 10-40270 Foreign identifier: QDe.160 Name: Tariq Gidar Group (TGG)

Good quality a.k.a.: a) Tehrik-e-Taliban-Tariq Gidar Group b) TTP-Tariq Gidar Group c) Tehreek-I-Taliban Pakistan Geedar Group d) TTP Geedar Group e) Tariq Geedar Group f) Commander Tariq Afridi Group g) Tariq Afridi Group h) Tariq Gidar Afridi Group i) The Asian Tigers Address: Afghanistan/ Pakistan border region

Relation: Splinter group of Tehrik-e Taliban Pakistan (TTP) (QE.T.132.11., SSID 10-17777) Other information: Splinter group of Tehrik-e Taliban Pakistan (TTP) (QDe.132). The group was formed in Darra Adam Khel, Federally Administered Tribal Area (FATA), Pakistan, in 2007. INTERPOL-UN Security Council Special Notice web link available. Modifications: Listed on 22 Mar 2019

to its Al-Qaida/bin Laden/Taliban counter terrorism sanctions program.

Links:

FINMA Notice

Data files of updates – PDF, XML

HKMA Alert: Fraudulent United Overseas Bank websites

$
0
0

Press Releases

Fraudulent websites related to United Overseas Bank Ltd.

The Hong Kong Monetary Authority (HKMA) wishes to alert members of the public to a press release issued by United Overseas Bank Ltd. on fraudulent websites, which has been reported to the HKMA. Hyperlink to the press release is available on the HKMA website for ease of reference by members of the public.

Anyone who has provided his or her personal information to the websites concerned or has conducted any financial transactions through the websites should contact the bank concerned using the contact information provided in the press release, and report to the Police or contact the Cyber Security and Technology Crime Bureau of the Hong Kong Police Force at 2860 5012.

 

Hong Kong Monetary Authority
5 March 2019

Link:

HKMA Notice

FINMA shuts down illegal ICO

$
0
0

FINMA ascertains illegal activity by envion AG

The Swiss Financial Market Supervisory Authority FINMA has found that envion AG (now in liquidation) unlawfully received public deposits on a commercial basis from at least 37,000 investors. The company is currently being liquidated by the Zug bankruptcy authority.

In March 2019, FINMA concluded the enforcement proceedings against envion AG, which it launched in July 2018 (press release). As part of its proceedings, FINMA appointed an investigating agent to investigate suspicious activity on site. It was discovered during this that the company had unlawfully accepted funds amounting to over 90 million francs from at least 37,000 investors in the context of an initial coin offering (ICO) without the necessary statutory licence. The company was thus acting illegally and seriously violated supervisory law. 

ICOs can fall within the scope of the Banking Act

In the context of its ICO envion AG issued so-called EVN tokens. Investors were able to purchase these tokens by making payments in US dollars as well as in the Ethereum and Bitcoin cryptocurrencies. Envion AG granted the token owners a claim to repayment after thirty years. Furthermore, the conditions for the EVN tokens issued in a bond-like form were not equal for all investors, the prospectuses did not meet the minimum statutory requirements and there was no internal audit unit as required by law. In the present case, this acceptance of US dollars and the Ethereum and Bitcoin cryptocurrencies therefore amounted to an acceptance of public deposits for the purposes of the Banking Act. This however requires a banking licence. 

No further intervention by FINMA necessary

While the FINMA proceedings were ongoing, the Cantonal Court of Zug opened bankruptcy proceedings against envion AG on grounds of organisational shortcomings. As a result, further supervisory measures against the company by FINMA will not be required. FINMA cannot provide information regarding the financial situation of envion AG as the bankruptcy proceedings are controlled by the Bankruptcy Office of Zug. 

FINMA will continue to focus on ICOs

FINMA will continue to consistently take action against ICO business models which violate or circumvent supervisory law. Ultimately, this can lead to the company being liquidated by FINMA. FINMA is committed to ensuring that serious innovators can launch their ICO projects lawfully and has published guidelines to this effect. In addition, FINMA informs FinTech service providers about requirements under financial market law on its website. FINMA has also already repeatedly pointed out the risks associated with ICOs to investors. Specifically, FINMA warns about unclear provisions or overly optimistic promises made in the whitepapers or published by companies which are planning to conduct an ICO.

Contact

Vinzenz Mathys, Media Spokesperson 
Tel. 031 327 19 77
vinzenz.mathys@finma.ch

Link:

FINMA Notice

In-force date for no-deal Brexit OGEL updated to April 12th

$
0
0
DIT logo

As we have previously notified, if the UK leaves the EU without a deal, dual-use items from the UK to the EU will need a licence. An Open General Export Licence (OGEL) has been created for this purpose.

This licence will come into force at 11pm on 11 April 2019 if the UK leaves the EU without a deal. 

For general export control queries please contact our Helpline on 020 7215 4594or exportcontrol.help@trade.gov.uk

Business Awareness Unit  

Export Control Joint Unit

However, a second email went out a bit later correcting that date to April 12th…


OFAC Enforcement Action: Hopefully, the 3rd time is the charm…

$
0
0

This is the third enforcement action just this year that is focused on oversight of subsidiaries… since this seems to be a pattern in enforcement, and since it’s against a name company (Stanley Black & Decker), I am posting this in full. You’ll see that it has hints of both the Kollmorgen Corporation and AppliChem GmbH actions:

Stanley Black & Decker, Inc. Settles Potential Civil Liability for Apparent Violations of the Iranian Transactions and Sanctions Regulations Committed by its Chinese-Based Subsidiary Jiangsu Guoqiang Tools Co. Ltd.:

Stanley Black & Decker, Inc. (“Stanley Black & Decker”), a company based in New Britain, Connecticut, on behalf of itself and its subsidiary located in China, Jiangsu Guoqiang Tools Co. Ltd. (“GQ”), has agreed to pay $1,869,144 to settle its potential civil liability for 23 apparent violations of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR). Specifically, between on or about June 29, 2013 and on or about December 30, 2014, GQ exported and attempted to export 23 shipments of power tools and spare parts, with a total value of $3,201,647.73, to Iran or to a third country with knowledge that such goods were intended specifically for supply, transshipment, or reexportation, directly or indirectly, to Iran, which would have been prohibited if engaged in by a U.S. person, under §§ 560.203 and 560.204 of the ITSR. These transactions appear to have violated § 560.215 of the ITSR (referred to hereafter as the “Apparent Violations”).

OFAC determined that Stanley Black & Decker voluntarily self-disclosed the Apparent Violations on behalf of GQ, and that the apparent violations constitute an egregious case. The statutory maximum civil monetary penalty amount for the Apparent Violations is $6,922,757, and the base civil monetary penalty amount for the Apparent Violations is $3,461,378.

Stanley Black & Decker began acquisition negotiations with GQ in 2011, during which it engaged in due diligence and discovered GQ exported to Iran. Stanley Black & Decker took steps to encourage GQ to cease sales to, and transactions with, Iran prior to the acquisition date and made ceasing such sales a prerequisite condition of the closing. GQ’s representatives agreed to these terms and conditions. In May 2013, Stanley Black & Decker acquired a 60 percent interest in GQ and created a joint venture with the firm.

Subsequent to its acquisition of GQ, Stanley Black & Decker provided a series of trainings to GQ’s employees on the company’s business conduct guidelines, the Foreign Corrupt Practices Act, and sanctions. Specifically, in early August 2013 a Stanley Black & Decker Global Trade Compliance for China employee reviewed the company’s trade compliance policies and procedures with GQ’s Manager for Export Sales by telephone. After this one training session, the individual who conducted the training asked the GQ Manager for Export Sales to provide the same training to her team within GQ, and to designate two members of her team to attend additional training on a customer screening tool. However, Stanley Black & Decker did not implement procedures to monitor or audit GQ’s operations to ensure that its Iran-related sales did not recur post-acquisition.

Despite the written agreements GQ’s senior management executed in which they attested that GQ would not engage in transactions with Iran, and notwithstanding the above-referenced trainings Stanley Black & Decker provided, GQ continued to export goods to Iran throughout 2013 and 2014. Once Stanley Black & Decker became aware of the potential violations of U.S. economic sanctions, it initiated an internal investigation, subsequently hired a third-party independent investigative company, and ultimately reported the matter to OFAC.

Stanley Black & Decker’s internal investigation determined various GQ board members and senior management participated in these activities with knowledge that such conduct violated its parent company’s policies and U.S. economic sanctions against Iran. These personnel and other GQ employees appear to have engaged in non-routine business practices in order to conceal and facilitate GQ’s prohibited exports to Iran. GQ utilized six trading companies as conduits for these sales — four companies located in the United Arab Emirates and two companies located in China. In addition, GQ employees created fictitious bills of lading with incorrect ports of discharge and places of delivery and instructed their customers not to write “Iran” on business documents, such as bills of lading.

For more information regarding the conduct that led to the apparent violations, please see the Settlement Agreement between OFAC and Stanley Black & Decker here.

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.

OFAC considered the following to be aggravating factors:

(1) GQ, and its senior management, including two board members and an export sales manager, willfully violated the ITSR when it exported and attempted to export, reexport, sell, or supply power tools and spare parts directly or indirectly to Iran with knowledge that such activities constituted apparent violations of U.S. economic sanctions regulations and laws;

(2) GQ caused harm to the objectives of the ITSR by conferring an economic benefit to Iran over an 18-month period, in a systematic scheme involving a series of transactions that occurred on a continuing basis; and

(3) GQ is a sophisticated company with a history of extensive export operations, with executive leadership who had knowledge of U.S. economic sanctions.

OFAC considered the following to be mitigating factors:

(1) Neither Stanley Black & Decker nor GQ have received a penalty notice or Finding of Violation from OFAC in the five years preceding the earliest transaction giving rise to the apparent violations;

(2) Upon learning of GQ’s apparent violations, Stanley Black & Decker implemented immediate and substantive remedial efforts, including halting all GQ exports, hiring an independent investigator; and

(3) Stanley Black & Decker cooperated with OFAC’s investigation by conducting an extensive investigation and producing the results to OFAC, responding to OFAC’s requests for additional information with detailed records and meaningful clarifications, and signed multiple tolling agreements to extend the statute of limitations.

Consistent with its Settlement Agreement with OFAC, Stanley Black & Decker has committed to enhancing GQ’s compliance procedures by ensuring that it has a management team in place that: (1) is committed to a culture of compliance; (2) conducts regular risk assessments to ensure that its internal controls appropriately mitigate the entity’s sanctions-related risks; (3) conducts regularized audits; and (4) provides ongoing sanctions compliance training throughout GQ.

This enforcement actions highlights the importance for U.S. companies to conduct sanctions- related due diligence both prior and subsequent to mergers and acquisitions, and to take appropriate steps to audit, monitor, and verify newly acquired subsidiaries and affiliates for OFAC compliance. U.S.-owned or -controlled foreign subsidiaries are subject to the ITSR and U.S. person parent companies may face potential exposure to civil monetary penalties vis-à-vis the actions of their foreign subsidiaries. Foreign acquisitions can pose unique risks that U.S. person parent companies need to address fully at all stages of its relationship with the subsidiary. U.S. parent companies are encouraged to take steps to mitigate risk to sanctions exposure, including by addressing known deficiencies like unconventional record-keeping practices, and any hindrances to monitoring, auditing, or investigating the foreign subsidiary’s operations. Testing of compliance procedures and timely auditing of subsidiaries can mitigate the risk of exposure to U.S. economic sanctions violations. For more information regarding OFAC regulations, please go to: http://www.treasury.gov/ofac.

Links:

OFAC Notice

OFAC Enforcement Information

Finanstilsynet AML Inspection: Sparekassen Sjælland-Fyn A / S

$
0
0

Report on inspection in Sparekassen Sjælland-Fyn A / S (whitewash area)

In June 2018, the Danish FSA was inspected by Sparekassen Sjælland-Fyn A / S. The inspection was a study of the money laundering area as part of the ongoing supervision of the bank.

The inspection included the bank’s risk assessment, policies, procedures and internal controls as well as customer knowledge procedures, including surveillance of private customers and corporate customers.

Risk assessment and summary

Sparekassen’s business model is based on being a significant bank in its local area for private customers, small and medium-sized enterprises, public institutions, cultural institutions and leisure associations. The savings bank limits its business to basic and simple products and does not have complex or speculative financial products.

The Danish Financial Supervisory Authority considers that the savings bank’s inherent risk of being abused for money laundering or terrorist financing is normal to high in relation to the average of financial companies in Denmark. In the assessment, special emphasis has been placed on the Savings Bank offering a number of financial products for both private customers and corporate customers. Conversely, Sparekassen restricts its business to traditional financial products and primarily takes its starting point in its local area with customers who are resident in Denmark.

Sparekassen has added additional resources to the money laundering area and initiated a money laundering project, which focuses on several areas, including onboarding of corporate customers.

On the basis of the inspection, however, there are a number of areas that give rise to supervisory reactions.

The Danish Financial Supervisory Authority found that the Savings Bank’s risk assessment does not adequately contain a documented analysis of the Savings Bank’s risk factors and does not adequately address the risk that the Savings Bank will be abused for financing terrorism. On this basis, the savings bank is ordered to revise the risk assessment accordingly.

In addition, the Savings Bank is required to revise its money laundering policy so that it clearly identifies and delimits the risks the Savings Bank wishes to assume in the money laundering area.

The savings bank also receives an order to ensure that adequate customer knowledge procedures are implemented for all customers, including obtaining information on purpose and intended nature regarding the customer relationship for all customers, as well as obtaining information on real owners for all corporate customers.

In addition, the Savings Bank is required to ensure that the information on purpose and intended nature can be used by the Savings Bank’s electronic surveillance.

In addition, the Savings Bank is required to obtain documentation for customers’ information in connection with investigating suspicious transactions.

Finally, the Savings Bank is instructed to ensure that there is the necessary independence between its compliance function and the money laundering officer, including that there is no personal association between the Savings Bank’s compliance manager and the money laundering employee.

Link:

Finanstilsynet Notice

EU, OFSI synchronize the Tariq Gidar Group listing…

$
0
0

Earlier today, UK regulators updated the following listing:

1. TARIQ GIDAR GROUP (TGG)

a.k.a: (1) COMMANDER TARIQ AFRIDI GROUP (2) TARIQ AFRIDI GROUP (3) TARIQ GEEDAR GROUP (4) TARIQ GIDAR AFRIDI GROUP (5) TEHREEK-I-TALIBAN PAKISTAN GEEDAR GROUP (6) TEHRIK-E-TALIBAN-TARIQ GIDAR GROUP (7) THE ASIAN TIGERS (8) TTP GEEDAR GROUP (9) TTP-TARIQ GIDAR

GROUP Address: Afghanistan/Pakistan border region. Other Information: UN Ref: QDe.160. Splinter group of Tehrik-e Taliban Pakistan (TTP) (QDe.132). The group was formed in Darra Adam Khel, Federally Administered Tribal Area (FATA), Pakistan, in 2007. (Listing to be treated as temporary for 30 days from the date of listing by the UN or until the EU adds the new listing to an existing sanctions regulation (whichever is sooner) in accordance with Policing and Crime Act 2017). UN Listing (formerly temporary listing, in accordance with Policing and Crime Act 2017). Listed on: 25/03/2019 Last Updated: 25/03/2019 28/03/2019 Group ID: 13786

to reflect the passage of Commission Implementing Regulation (EU) 2019/507.

Links:

OFSI Notice

Commission Implementing Regulation (EU) 2019/507

HKMA Alert: HSBC Phishing Email

$
0
0

Press Releases

Phishing email related to The Hongkong and Shanghai Banking Corporation Limited

The Hong Kong Monetary Authority (HKMA) wishes to alert members of the public to a press release issued by The Hongkong and Shanghai Banking Corporation Limited on phishing email, which has been reported to the HKMA.  Hyperlink to the press release is available on the HKMA website for ease of reference by members of the public.

Anyone who has provided his or her personal information to the email concerned or has conducted any financial transactions through the email should contact the bank concerned using the contact information provided in the press release, and report to the Police or contact the Cyber Security and Technology Crime Bureau of the Hong Kong Police Force at 2860 5012.

 

Hong Kong Monetary Authority
19 February 2019

Link:

HKMA Notice

HKMA Alert: HSBC Phishing Emails

$
0
0

Press Releases

Phishing emails related to The Hongkong and Shanghai Banking Corporation Limited

The Hong Kong Monetary Authority (HKMA) wishes to alert members of the public to a press release issued by The Hongkong and Shanghai Banking Corporation Limited on phishing e-mails, which has been reported to the HKMA. Hyperlink to the press release is available on the HKMA website for ease of reference by members of the public.

Anyone who has provided his or her personal information to the e-mails concerned or has conducted any financial transactions through the e-mails should contact the bank concerned using the contact information provided in the press release, and report to the Police or contact the Cyber Security and Technology Crime Bureau of the Hong Kong Police Force at 2860 5012.

 

Hong Kong Monetary Authority
11 March 2019

Link:

HKMA Notice

April 1, 2019: UN, OSFI update 6 on counter terror list

$
0
0

On Monday, Canadian officials amended the following 6 individual listings modified by the United Nations ISIL (Da’esh) and Al-Qaida Sanctions Committee last Friday:

QDi.001 Name: 1: SAYF-AL ADLMohammed 2: n.a.Salahaldin3: n.a.Abd El Halim 4: n.a. Zidane 
Name (original script): سيف العدل محمد صلاح الدين عبدالحليم زيدان
Title: na Designation: na DOB: (a) 11 Apr. 1963 (b) 11 Apr. 1960POB: Monufia Governate, Egypt Good quality a.k.a.: a) Mohammed Salahaldin Abd El Halim ZidanSayf-Al Adl (DOB: 11 Apr. 1963. POB: Monufia Governorate, Egypt. Nationality: Egypt. In Arabic: محمد صلاح الدين عبدالحليم زيدان سيف العدل b) Muhamad Ibrahim Makkawi (DOB: a) 11 Apr. 1960 b) 11 Apr. 1963. POB: Egypt. Nationality: Egypt) Low quality a.k.a.: a) Ibrahim al-Madani b) Saif Al-‘Adil c) Seif al Adel Nationality: Egypt Passport no: na National identification no: na Address: na Listed on: 25 Jan. 2001 (amended on 16 Dec. 2010, 24 Jul. 2013, 15 Feb. 2017, 29 Mar. 2019Other information: Responsible for Usama bin Laden’s (deceased) security. Hair: Dark. Eyes: Dark. Photo available for inclusion in the INTERPOL-UN Security Council Special Notice. Review pursuant to Security Council resolution 1822 (2008) was concluded on 15 Jun. 2010. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb. 2019. INTERPOL-UN Security Council Special Notice web link:  https://www.interpol.int/en/notice/search/un/4681065.

QDi.123 Name: 1: YASSIN 2: SYAWAL 3: na 4: na
Title: na Designation: na DOB: Approximately 19723 Sept. 1962POB: naMakassar, Indonesia Good quality a.k.a.: a) Salim Yasin b) Yasin Mahmud Mochtar c) Abdul Hadi Yasin d) Muhamad Mubarok e) Muhammad Syawal f) Yassin Sywal (formerly listed as) Low quality a.k.a.: a) Abu Seta b) Mahmud c) Abu Muamar d) Mubarok Nationality: Indonesia Passport no: na National identification no: na Address: na Listed on: 9 Sep. 2003 (amended on 12 Dec. 2014, 29 Mar. 2019Other information: At large as at Dec. 2003. Review pursuant to Security Council resolution 1822 (2008) was concluded on 25 May 2010. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb. 2019. INTERPOL-UN Security Council Special Notice web link:   https://www.interpol.int/en/notice/search/un/1424789.

QDi.144 Name: 1: MOHAMMAD 2: TAHIR 3: HAMMID 4: HUSSEIN
Name (original script: حسين محمد طاهر حامد
Title: Imam Designation: na DOB: 1 Nov. 1975 POB: Poshok, Iraq Good quality a.k.a.: Abdelhamid Al Kurdi Low quality a.k.a.: na Nationality: Iraq Passport no: na National identification no: na Address: Sulaymaniya, Iraq Listed on: 12 Nov. 2003 (amended on 9 Sep. 2005, 21 Dec. 2007, 16 May 2011, 10 Dec. 2015, 29 Mar. 2019Other information: Mother’s name: Attia Mohiuddin Taha. A deportation order was issued by the Italian authorities on 18 Oct. 2004. Considered a fugitive from justice by the Italian authorities as of Sep. 2007. Review pursuant to Security Council resolution 1822 (2008) was concluded on 8 Jun. 2010. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb. 2019. INTERPOL-UN Security Council Special Notice web link:  https://www.interpol.int/en/notice/search/un/1424109.

QDi.250 Name: 1: AMOR 2: MOHAMED 3: GHEDEIR 4: na
Name (original script): عمر محمد قدير
Title: na Designation: na DOB: Approximately 1958 POB: Deb-Deb, Amenas, Wilaya (province) of Illizi, Algeria Good quality a.k.a.: a) Abdelhamid Abou Zeid b) Youcef Adel c) Abou Abdellah d) Abid Hammadou born 12 Dec. 1965 in Touggourt, Wilaya (province) of Ouargla, Algeria (previously listed as) Low quality a.k.a.: na Nationality: Algeria Passport no: na National identification no: na Address: na Listed on: 3 Jul. 2008 (amended on 10 May 2012, 15 Nov. 2012, 29 Mar. 2019Other information: Associated with the Organization of Al-Qaida in the Islamic Maghreb (QDe.014). Located in Northern Mali as of Jun. 2008. Mother’s name is Benarouba Bachira. Father’s name is Mabrouk. He usurped the identity of Abid Hammadou, who allegedly died in Chad in 2004. Reportedly deceased as of 24 February 2013. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb. 2019. INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/notice/search/un/1529259.

QDi.319 Name: 1: MOHAMED 2: LAHBOUS 3: na 4: na
Name (original script): محمد لحبوس
Title: na Designation: na DOB: 1978 POB: Mali Good quality a.k.a.: a) Mohamed Ennouini b) Hassan c) Hocine Low quality a.k.a.: na Nationality: Mali Passport no: na National identification no: na Address: Mali Listed on: 24 Oct. 2013 (amended on 29 Mar. 2019) Other information: Member of the Mouvement pour l’Unification et le Jihad en Afrique de l’Ouest (MUJAO) (QDe.134). Reportedly deceased as of 14 February 2018. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb. 2019 INTERPOL-UN Security Council Special Notice web link:  https://www.interpol.int/en/notice/search/un/5720103.

QDi.374 Name: 1: NUSRET 2: IMAMOVIC 3: na 4: na
Title: na Designation: na DOB: a) 26 Sep. 1971 b) 26 Sep. 1977 POB: naMiljanovci, Kalesija Municipality, Bosnia Good quality a.k.a.: Nusret Sulejman Imamovic Low quality a.k.a.: na Nationality: Bosnia and Herzegovina Passport no: a) Bosnia and Herzegovina number 349054 b) Bosnia and Herzegovina number 3490054 National identification no: na Address: Syrian Arab Republic (location as at Sep. 2015) Listed on: 29 Feb. 2016 (amended on 29 Mar. 2019) Other information: Believed to be fighting with Al-Nusrah Front for the People of the Levant (QDe.137) in Syrian Arab Republic and reported to be a leader in the group as of Apr. 2015. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb. 2019. INTERPOL-UN Security Council Special Notice web link:  https://www.interpol.int/en/notice/search/un/5930702.

Links:

OSFI Notice

UN Notice

April 1, 2019: FINTRAC publishes FATF advisory

$
0
0

April 1, 2019 – FINTRAC Advisory: Financial transactions related to countries identified by the Financial Action Task Force (FATF) 

On February 22, 2019, the Financial Action Task Force (FATF) issued a Public Statement and a statement on Improving Global AML/CFT Compliance. These statements are updated and released following every Plenary.

The Public Statement identifies jurisdictions for which the FATF has called on its members to apply countermeasures or enhanced due diligence. The Improving Global AML/CFT Compliance statement identifies those jurisdictions which have developed an action plan with the FATF to address their strategic AML/CFT deficiencies.

Financial transactions related to countries identified by the FATF

Democratic People’s Republic of Korea (DPRK)

As communicated in the Public Statement dated 22 February 2019, the FATF:

“Remains concerned by the DPRK’s failure to address the significant deficiencies in its anti-money laundering and combatting the financing of terrorism (AML/CFT) regime and the serious threats they pose to the integrity of the international financial system. Further, the FATF has serious concerns with the threat posed by the DPRK’s illicit activities related to the proliferation of weapons of mass destruction (WMDs) and its financing.

The FATF reaffirms its 25 February 2011 call on its members and urges all jurisdictions to advise their financial institutions to give special attention to business relationships and transactions with the DPRK, including DPRK companies, financial institutions, and those acting on their behalf. In addition to enhanced scrutiny, the FATF further calls on its members and urges all jurisdictions to apply effective counter-measures, and targeted financial sanctions in accordance with applicable United Nations Security Council Resolutions, to protect their financial sectors from money laundering, financing of terrorism and WMD proliferation financing (ML/FT/PF) risks emanating from the DPRK. Jurisdictions should take necessary measures to close existing branches, subsidiaries and representative offices of DPRK banks within their territories and terminate correspondent relationships with DPRK banks, where required by relevant UNSC resolutions.”

Ministerial directive on the DPRK

Accordingly, in order to safeguard the integrity of Canada’s financial system, and in accordance with section 11.42 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)Footnote 1, the Minister of Finance has issued the following directive as published in the Canada Gazette on December 9, 2017:

“Every person or entity referred to in section 5 of the PCMLTFA shall treat all transactions originating from, or destined to, North Korea (Democratic People’s Republic of Korea) as high risk for the purposes of subsection 9.6(3) of the Act.”

The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) has issued guidance related to the Ministerial Directive which can be found on its website. FINTRAC will assess compliance with the Ministerial Directive.

In addition, on December 12, 2017, FINTRAC published an Operational Alert on the DPRK’s use of the international financial system for money laundering and terrorist activity financing. The purpose of this Operational Alert is to inform Canadian reporting entities of the patterns and risk areas related to the DPRK’s suspected money laundering and terrorist activity financing.

Iran

As communicated in the Public Statement dated 22 February 2019, the FATF welcomed Iran’s high-level political commitment to address its strategic AML/CFT deficiencies in June 2016. However:

“Until Iran implements the measures required to address the deficiencies identified with respect to countering terrorism-financing in the Action Plan, the FATF will remain concerned with the terrorist financing risk emanating from Iran and the threat this poses to the international financial system. The FATF, therefore, calls on its members and urges all jurisdictions to continue to advise their financial institutions to apply enhanced due diligence with respect to business relationships and transactions with natural and legal persons from Iran, consistent with FATF Recommendation 19, including: (1) obtaining information on the reasons for intended transactions; and (2) conducting enhanced monitoring of business relationships, by increasing the number and timing of controls applied, and selecting patterns of transactions that need further examination.”

Accordingly, FINTRAC is reiterating to all reporting entities subject to the requirements of the PCMLTFA, the risks of doing business with individuals and entities based in, or connected to, Iran.

FINTRAC is advising that reporting entities should consider the above in determining whether they are required to file a suspicious transaction reportFootnote 2 in respect of one or more financial transaction(s) or attempted financial transaction(s) emanating from, or destined to, Iran. FINTRAC guidance related to suspicious transaction reports can be found on our website.

In addition, reporting entities are required to consider the geographic location of a person’s or entity’s activities as part of their risk assessment under their Compliance ProgramFootnote 3 and to undertake mitigating measures, as applicable. Reporting entities are encouraged to undertake enhanced customer due diligence, including obtaining information on the reasons for intended transactions, with respect to clients and beneficiaries involved in such financial transactions or attempted financial transactions.

Other jurisdictions

In its compliance document dated 22 February 2019, the FATF brought to the attention of its members several jurisdictions that have strategic AML/CFT deficiencies. The following jurisdictions have developed an action plan with the FATF to address identified deficiencies and have demonstrated some progress with the execution of their plans: the Bahamas, Botswana, Cambodia, Ethiopia, Ghana, Pakistan, Serbia, Sri Lanka, Syria, Trinidad and Tobago, Tunisia, and Yemen.

FATF action on the terrorist group Islamic StateFootnote 4

On September 22, 2014, the Government of Canada updated the Criminal Code list of terrorist entities to include the Islamic State (IS), which was previously listed as Al Qaeda in Iraq.

FINTRAC would like to reiterate previous statements issued by the FATF, expressing its deep concern with the financing generated by, and provided to, the terrorist group known as the Islamic State.

Accordingly, FINTRAC is reminding all reporting entities subject to the requirements of the PCMLTFA of their obligationFootnote 5 to submit a terrorist property report (TPR) to FINTRAC without delay, once they have met the threshold to disclose under the Criminal Code or the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism (RIUNRST). Guidance related to TPRs can be found on FINTRAC’s website.Footnote 6

In this context, property includes any type of real or personal property. This also includes any deed or instrument giving title or right to property, or giving a right to recover or receive money or goods. A terrorist property report includes information about the property as well as any transaction or attempted transaction relating to that property.

FINTRAC is advising that reporting entities should consider the above in determining whether to file a suspicious transaction report in respect of one or more financial transactions emanating from, or destined to, a jurisdiction under IS control or a surrounding jurisdiction where there are reasonable grounds to suspect that the transactions or attempted transactions are related to the commission or attempted commission of a money laundering offence or a terrorist activity financing offence.

Reporting entities are also encouraged to undertake enhanced customer due diligence with respect to clients and beneficiaries involved in such financial transactions or attempted financial transactions.Footnote 7

Link:

FINTRAC Advisory


OCC Counterfeit Check Alert: First National Bank of Elmer, Elmer, NJ

$
0
0
Office of the Comptroller of the Currency  
Office of the Comptroller of the Currency
Ensuring a safe and sound Federal Banking System for All Americans
 
Alert 2019-2
Subject: Counterfeit Cashier’s Checks
Date: March 13, 2019
Description: First National Bank of Elmer
 

Counterfeit Cashier’s Checks of the First National Bank of Elmer, Elmer, NJ

To: Chief Executive Officers of All National Banks and Federal Savings Associations; All State Banking Authorities; Chair, Board of Governors of the Federal Reserve System; Chair, Federal Deposit Insurance Corporation; Conference of State Bank Supervisors; Deputy Comptrollers (Districts); Assistant Deputy Comptrollers; District Counsels; and All Examining Personnel

The above-named bank has reported that counterfeit cashier’s checks using the bank’s routing number of 031203915are being presented for payment nationwide in connection with an online job opportunity overpayment scam.

While the counterfeit checks resemble the bank’s authentic items, counterfeits may be identified by the following traits:

  • The checks are blue with white marbling and contain a dark top border with the following security statement: “THIS DOCUMENT HAS A COLORED BACKGROUND AND MICROPRINTING. THE REVERSE SIDE INCLUDES AN ARTIFICIAL WATERMARK.”
  • The bank’s address appears as “PO BOX Elmer NJ 08318.” The actual box number is missing.
  • The words “CASHIERS CHECK” appear in the top center portion of the check but are not encircled.
  • The ABA number is located beneath and to the left of the check number.
  • The written dollar amount line contains empty space after the amount.
  • The numerical dollar amount is not underlined.
  • The account number in the micro line at the bottom of the check is preceded by four zeros.

Checks presented to date have been made payable in amounts ranging from $1,300 to $100,000 and contain a remitter name of Robert White.

Potential victims have been contacted via email by David Netto using an email address of [Davidnetto101@protonmail.com]. The email correspondence introduces Mr. Netto as a writer for a well-known magazine, who is advertising for a professional photographer. Counterfeit checks that are sent to potential victims are made payable for an amount greater than the agreed-upon amount. The potential victim is told to deposit the counterfeit check and immediately wire the overage amount to a third party.

For additional information and to verify the authenticity of cashier’s checks drawn on the First National Bank of Elmer, please contact Vice President and Risk Officer Steven Botto by mail at 10 South Main Street, Elmer, NJ 08318, by telephone at (856) 358-7000, x1119, or by email at sbotto@elmerbank.com.

Consumers who receive counterfeit or fictitious items and associated material should file complaints with the following agencies, as appropriate:

  • U.S. Department of the Treasury, Office of Inspector General (OIG): by telephone at (800) 359 3898 or by visiting the OIG website.
  • Federal Trade Commission (FTC): by telephone at (877) FTC-HELP or, for filing a complaint electronically, via the FTC’s website.
  • National Consumers League (NCL): by telephone at (202) 835-3323 or by e-mail. To file a fraud complaint, visit the NCL fraud website.
  • Better Business Bureau (BBB): The BBB system serves markets throughout Canada, Puerto Rico, and the United States and is the marketplace leader in advancing trust between businesses and consumers. The website offers contact information for local BBBs, objective reports on more than 2 million businesses, consumer scam alerts, and tips on a wide variety of topics that help consumers find trustworthy businesses and make wise purchasing decisions.
  • Federal Bureau of Investigation Internet Crime Complaint Center (to report scams that may have originated via the internet).
  • If correspondence is received via the U.S. Postal Service, contact the U.S. Postal Inspection Service by telephone at (888) 877-7644; by mail at U.S. Postal Inspection Service, Office of Inspector General, Operations Support Group, 222 S. Riverside Plaza, Suite 1250, Chicago, IL 60606-6100; or via the online complaint form.

Additional information concerning this matter that should be brought to the attention of the Office of the Comptroller of the Currency (OCC) may be forwarded to

Office of the Comptroller of the Currency
Special Supervision Division
400 7th St. SW, Suite 3E-218; MS 8E-12
Washington, DC 20219
Phone: (202) 649-6450
Fax: (571) 293-4925
www.occ.gov
occalertresponses@occ.treas.gov

For additional information regarding other types of financial fraud, please visit the OCC’s anti-fraud resources page.

 

Monica A. Freas
Director for Enforcement and Compliance


Link:

OCC Notice

April 1, 2019: UN, DFAT modify 6 counter terror listings

$
0
0

On Monday, Australian regulators amended:

QDi.001 Name: 1: SAYF-AL ADLMohammed 2: n.a.Salahaldin3: n.a.Abd El Halim 4: n.a. Zidane 
Name (original script): سيف العدل محمد صلاح الدين عبدالحليم زيدان
Title: na Designation: na DOB: (a) 11 Apr. 1963 (b) 11 Apr. 1960 POB: Monufia Governate, Egypt Good quality a.k.a.: a) Mohammed Salahaldin Abd El Halim ZidanSayf-Al Adl (DOB: 11 Apr. 1963. POB: Monufia Governorate, Egypt. Nationality: Egypt. In Arabic: محمد صلاح الدين عبدالحليم زيدان سيف العدل b) Muhamad Ibrahim Makkawi (DOB: a) 11 Apr. 1960 b) 11 Apr. 1963. POB: Egypt. Nationality: Egypt) Low quality a.k.a.: a) Ibrahim al-Madani b) Saif Al-‘Adil c) Seif al Adel Nationality: Egypt Passport no: na National identification no: na Address: na Listed on: 25 Jan. 2001 (amended on 16 Dec. 2010, 24 Jul. 2013, 15 Feb. 2017, 29 Mar. 2019Other information: Responsible for Usama bin Laden’s (deceased) security. Hair: Dark. Eyes: Dark. Photo available for inclusion in the INTERPOL-UN Security Council Special Notice. Review pursuant to Security Council resolution 1822 (2008) was concluded on 15 Jun. 2010. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb. 2019. INTERPOL-UN Security Council Special Notice web link:  https://www.interpol.int/en/notice/search/un/4681065.

QDi.123 Name: 1: YASSIN 2: SYAWAL 3: na 4: na
Title: na Designation: na DOB: Approximately 19723 Sept. 1962 POB: naMakassar, Indonesia Good quality a.k.a.: a) Salim Yasin b) Yasin Mahmud Mochtar c) Abdul Hadi Yasin d) Muhamad Mubarok e) Muhammad Syawal f) Yassin Sywal (formerly listed as) Low quality a.k.a.: a) Abu Seta b) Mahmud c) Abu Muamar d) Mubarok Nationality: Indonesia Passport no: na National identification no: na Address: na Listed on: 9 Sep. 2003 (amended on 12 Dec. 2014, 29 Mar. 2019Other information: At large as at Dec. 2003. Review pursuant to Security Council resolution 1822 (2008) was concluded on 25 May 2010. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb. 2019. INTERPOL-UN Security Council Special Notice web link:   https://www.interpol.int/en/notice/search/un/1424789.

QDi.144 Name: 1: MOHAMMAD 2: TAHIR 3: HAMMID 4: HUSSEIN
Name (original script: حسين محمد طاهر حامد
Title: Imam Designation: na DOB: 1 Nov. 1975 POB: Poshok, Iraq Good quality a.k.a.: Abdelhamid Al Kurdi Low quality a.k.a.: na Nationality: Iraq Passport no: na National identification no: na Address: Sulaymaniya, Iraq Listed on: 12 Nov. 2003 (amended on 9 Sep. 2005, 21 Dec. 2007, 16 May 2011, 10 Dec. 2015, 29 Mar. 2019Other information: Mother’s name: Attia Mohiuddin Taha. A deportation order was issued by the Italian authorities on 18 Oct. 2004. Considered a fugitive from justice by the Italian authorities as of Sep. 2007. Review pursuant to Security Council resolution 1822 (2008) was concluded on 8 Jun. 2010. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb. 2019. INTERPOL-UN Security Council Special Notice web link:  https://www.interpol.int/en/notice/search/un/1424109.

QDi.250 Name: 1: AMOR 2: MOHAMED 3: GHEDEIR 4: na
Name (original script): عمر محمد قدير
Title: na Designation: na DOB: Approximately 1958 POB: Deb-Deb, Amenas, Wilaya (province) of Illizi, Algeria Good quality a.k.a.: a) Abdelhamid Abou Zeid b) Youcef Adel c) Abou Abdellah d) Abid Hammadou born 12 Dec. 1965 in Touggourt, Wilaya (province) of Ouargla, Algeria (previously listed as) Low quality a.k.a.: na Nationality: Algeria Passport no: na National identification no: na Address: na Listed on: 3 Jul. 2008 (amended on 10 May 2012, 15 Nov. 2012, 29 Mar. 2019Other information: Associated with the Organization of Al-Qaida in the Islamic Maghreb (QDe.014). Located in Northern Mali as of Jun. 2008. Mother’s name is Benarouba Bachira. Father’s name is Mabrouk. He usurped the identity of Abid Hammadou, who allegedly died in Chad in 2004. Reportedly deceased as of 24 February 2013. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb. 2019. INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/notice/search/un/1529259.

QDi.319 Name: 1: MOHAMED 2: LAHBOUS 3: na 4: na
Name (original script): محمد لحبوس
Title: na Designation: na DOB: 1978 POB: Mali Good quality a.k.a.: a) Mohamed Ennouini b) Hassan c) Hocine Low quality a.k.a.: na Nationality: Mali Passport no: na National identification no: na Address: Mali Listed on: 24 Oct. 2013 (amended on 29 Mar. 2019) Other information: Member of the Mouvement pour l’Unification et le Jihad en Afrique de l’Ouest (MUJAO) (QDe.134). Reportedly deceased as of 14 February 2018. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb. 2019 INTERPOL-UN Security Council Special Notice web link:  https://www.interpol.int/en/notice/search/un/5720103.

QDi.374 Name: 1: NUSRET 2: IMAMOVIC 3: na 4: na
Title: na Designation: na DOB: a) 26 Sep. 1971 b) 26 Sep. 1977 POB: naMiljanovci, Kalesija Municipality, Bosnia Good quality a.k.a.: Nusret Sulejman Imamovic Low quality a.k.a.: na Nationality: Bosnia and Herzegovina Passport no: a) Bosnia and Herzegovina number 349054 b) Bosnia and Herzegovina number 3490054 National identification no: na Address: Syrian Arab Republic (location as at Sep. 2015) Listed on: 29 Feb. 2016 (amended on 29 Mar. 2019) Other information: Believed to be fighting with Al-Nusrah Front for the People of the Levant (QDe.137) in Syrian Arab Republic and reported to be a leader in the group as of Apr. 2015. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb. 2019. INTERPOL-UN Security Council Special Notice web link:  https://www.interpol.int/en/notice/search/un/5930702.

in line with changes made by the United Nations ISIL (Da’esh) and Al-Qaida Sanctions Committee.

Link:

UN Notice

Notice to exporters 2019/05: ???

$
0
0

Notice

Notice to exporters 2019/05: UK company fined more than £80,000 for illegal exports

Published 3 April 2019

A little more detail would be nice, don’t you think? What were the value of the goods? How was the penalty amount derived?

Link:

Notice to exporters 2019/05

March 14, 2019: HK SFC AML/CTF Circular – UN Sanctions Early Alert

$
0
0

Circular to Licensed Corporations and Associated Entities 

Anti-Money Laundering / Counter-Financing of Terrorism

Early Alert on United Nations Sanctions 

The sanctions committee of the United Nations Security Council (“UNSC”) which administers the sanctions regime for ISIL (Da’esh) and Al-Qaida amended the detail of one individual on its sanctions list Note 1, 2 on 13 March 2019 (New York time).  Please refer to the relevant press release issued by the UNSC in Attachment 1.

Licensed corporations (“LCs”) and associated entities (“AEs”) should update their screening databases with the above change made by the UNSC sanctions committee for sanctions screening of customers and payments.  LCs and AEs are reminded to refer to our circular on United Nations Sanctions issued on 7 February 2018 Note 3 which sets out our expectations on actions that LCs and AEs should take regarding sanctions imposed by the UNSC.

Should you have any queries regarding the contents of this circular, please contact Ms Kiki Wong at 2231 1569 who will assist to refer your queries to the relevant officer.

Intermediaries Supervision Department
Intermediaries Division
Securities and Futures Commission

Enclosure

End

SFO/IS/008/2019

Note 1 An updated list specifying “individuals, groups, undertakings and entities”, reflecting the amendment by the sanctions committee of the UNSC, was published under section 25 of the United Nations Sanctions (ISIL and Al-Qaida) Regulation (Cap. 537CB) on the website of the Commerce and Economic Development Bureau on 14 March 2019. The list obtained from the website of the Commerce and Economic Development Bureau is attached in Attachment 2.
Note 2
 Licensed corporations and associated entities will also be alerted when the updated sanctions list, reflecting the amendment by the sanctions committee of the UNSC, is published under the United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575) in the Gazette. The website of the Securities and Futures Commission (“SFC”) will also be updated to provide a weblink to the gazette notice thereof for easy reference.
Note 3
 The circular on United Nations Sanctions can be accessed on the SFC’s website (http://www.sfc.hk/edistributionWeb/gateway/EN/circular/aml/aml-regulations/doc?refNo=18EC9)

Links:

HK SFC Notice

HK SFC Circular

UN Press Release (Attachment 1)

Updated Commerce and Economic Development Bureau List (Attachment 2)

April 2, 2019: SECO amends 6 counter terrorism listings

$
0
0

On Tuesday, Swiss officials updated the following listings under their Al-Qaida/bin Laden/Taliban counter terrorism sanctions:

SSID: 10-15641 Foreign identifier: QI.H.250.08. Name: Amor Mohamed Ghedeir

DOB: 1958 (approximately) POB: Deb-Deb, Amenas, Wilaya (province) of Illizi, Algeria Good quality a.k.a.: a) Abdelhamid Abou Zeid b) Youcef Adel c) Abou Abdellah Nationality: Algeria

Other identity: Abid Hammadou

DOB: 12 Dec 1965 POB: Touggourt, Wilaya (province) of Ouargla, Algeria

Relation: Associated with The Organization of Al-Qaida in the Islamic Maghreb (QE.T.14.01., SSID 10-17785) Other information: Associated with the Organization of Al- Qaida in the Islamic Maghreb (QE.T.14.01.). Located in Northern Mali as of Jun 2008. Mother’s name is Benarouba Bachira. Father’s name is Mabrouk. He usurped the identity of Abid Hammadou, who allegedly died in Chad in 20042004. Reportedly deceased as of 24 February 2013. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb 2019. INTERPOL-UN Security Council Special Notice web link available. Modifications: Amended on 14 Dec 2012, 29 Mar 2019

SSID: 10-15687 Foreign identifier: QI.H.144.03. Name: Mohammad Tahir Hammid Hussein

Title: Imam DOB: 1 Nov 1975 POB: Poshok, Iraq Good quality a.k.a.: Abdelhamid Al Kurdi Address: Sulaymaniya, Iraq Nationality: Iraq

Other information: Mother’s name: Attia Mohiuddin Taha. A deportation order was issued by the Italian authorities on 18 Oct 2004. Considered a fugitive from justice by the Italian authorities as of Sep 2007. Review pursuant to Security Council resolution 1822 (2008) was concluded on 8 Jun 20102010. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb 2019. INTERPOL-UN Security Council Special Notice web link available. Modifications: Amended on 17 Dec 2015, 29 Mar 2019

SSID: 10-16771 Foreign identifier: QI.S.1.01. Name: Sayf-Al AdlMohammed Salahaldin Abd El Halim Zidane

DOB: a) 11 Apr 1963 b) 11 Apr 1960 POB: Monufia Governorate, Egypt Low quality a.k.a.: a) Saif Al-‘AdilIbrahim al-Madani b) Seif al AdelSaif Al-‘Adil c) Ibrahim al-MadaniSeif al Adel Nationality: Egypt

Other identity: Mohammed Salahaldin Abd El Halim ZidanSayf-Al Adl

DOB: 11 Apr 1963 POB: Monufia Governorate, Egypt Nationality: Egypt

Other identity: Muhamad Ibrahim Makkawi

DOB: a) 11 Apr 1960 b) 11 Apr 1963 POB: Egypt Nationality: Egypt

Other information: Responsible for Usama bin Laden’sLaden’s (deceased) security. Hair: Dark. Eyes: Dark. Photo available for inclusion in the INTERPOL-UN Security Council Special Notice. Review pursuant to Security Council resolution 1822 (2008) was concluded on 15 Jun 20102010. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb 2019. INTERPOL-UN Security Council Special Notice web link available. Modifications: Amended on 9 Mar 2013, 14 Aug 2013, 15 Feb 2017, 29 Mar 2019

SSID: 10-16872 Foreign identifier: QI.S.123.03. Name: Yassin Syawal

DOB: 1972 (approximately)3 Sep 1962 POB: Makassar, Indonesia Good quality a.k.a.: a) Salim Yasin b) Yasin Mahmud Mochtar c) Abdul Hadi Yasin d) Muhamad Mubarok e) Muhammad Syawal Low quality a.k.a.: a) Abu Seta b) Mahmud c) Abu Muamar d) Mubarok F.k.a.: Yassin Sywal Nationality: Indonesia

Other information: At large as at Dec 2003. Review pursuant to Security Council resolution 1822 (2008) was concluded on 25 May 20102010. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb 2019. INTERPOL-UN Security Council Special Notice web link available. Modifications: Amended on 21 Jan 2015, 29 Mar 2019

SSID: 10-26311 Foreign identifier: QI.L.319.13. Name: Mohamed Lahbous

DOB: 1978 POB: Mali Good quality a.k.a.: a) Mohamed Ennouini b) Hassan c) Hocine Address: Mali Nationality: Mali

Relation: Member of the Mouvement pour l’Unification et le Jihad en Afrique de l’Ouest (MUJAO) (QE.M.134.12., SSID 10-23649) Other information: Member of the Mouvement pour l’Unification et le Jihad en Afrique de l’Ouest (MUJAO) (QE.M.134.12).QE.M.134.12). Reportedly deceased as of 14 February 2018. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb 2019. INTERPOL-UN Security Council Special Notice web link available. Modifications: Listed on 15 Nov 2013, amended on 29 Mar 2019

SSID: 10-33635 Foreign identifier: QDi.374 Name: Nusret Imamovic

DOB: a) 26 Sep 1971 b) 26 Sep 1977 POB: Miljanovci, Kalesija Municipality, Bosnia and Herzegovina Good quality a.k.a.: Nusret Sulejman Imamovic Address: Syrian Arab Republic (location as at Sep 2015) Nationality: Bosnia and Herzegovina Identification document: a) Passport No. 349054, Bosnia and Herzegovina b) Passport No. 3490054, Bosnia and Herzegovina

Relation: Fighting with Al-Nusrah Front For The People Of The Levant (QE.A.137.14., SSID 10-27843) Other information: Believed to be fighting with Al-Nusrah Front for the People of the Levant (QDe.137) in Syrian Arab Republic and reported to be a leader in the group as of Apr 20152015. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb 2019. INTERPOL-UN Security Council Special Notice web link available. Modifications: Listed on 3 Mar 2016, amended on 29 Mar 2019

Links:

FINMA Notice

Data files of updates – PDF, XML

Viewing all 8457 articles
Browse latest View live


<script src="https://jsc.adskeeper.com/r/s/rssing.com.1596347.js" async> </script>