Sina Bank wins EU Iran re-listing case

Sina Bank’s original EU Iran sanctions listing was annulled (see previous blog) because the reason given for its inclusion (“closely linked to the interests of ‘Daftar’… It contributes in this way to funding the regime’s strategic interests”) was too vague.  Its re-listing has now also been annulled by the General Court (link to the judgment here), although these measures have now been lifted by the JCPOA. The judgment states (in summary) that:

  • The Council should have written to the bank itself, not to its lawyers, about its designation.
  • One of the reasons for re-listing the bank (intended to show that the bank supported nuclear proliferation) was too vague, and also breached the applicant’s rights of defence and effective judicial protection. The other reason (designed to show that the bank was “controlled” by a person or entity engaged in or supporting nuclear proliferation) was not.
  • The Council erred in having re-listed Sina Bank on the grounds that it was “controlled by” the Supreme Leader and his foundation without designating either of them.

Ukraine renews and expands Russia sanctions

Ukraine’s President Petro Poroshenko has enacted the decision of the National Security and Defence Council of Ukraine last month to renew the country’s unilateral sanctions on Russia, and expand the list of people and entities subject to the sanctions for being involved in the violation of Ukraine’s territorial integrity.  The new listings target, among others, Russian military firms, financial institutions supporting the Luhansk and Donetsk People’s Republics, and sea and air transportation companies doing business with occupied parts of Crimea.  The President’s original press release is here.

EU expands list of prohibited exports to N Korea

The EU has implemented a UN Security Council decision to expand the list of goods that it is prohibited to transfer to, procure for, or provide technical assistance in, as regards North Korea.  The new list is in Annex Ig of Regulation 329/2007, as amended by Implementing Regulation 2016/1831.

Reza Zarrab’s sanctions extraterritoriality challenge rejected

Reza Zarrab, a Turkish-Iranian businessman charged in March 2016 with conspiring to evade US sanctions on Iran, has lost his application to have the case against him dismissed. He  is the first foreign national accused of violating US banking sanctions on Iran and said the prosecution was “a dangerous extension of US law that should not be allowed”.  District Judge Richard Berman said the U.S. has authority to bring these cases because it has to defend itself against Iran’s sponsorship of international terrorism and that U.S. anti-money-laundering law “applies to foreign nationals or persons acting outside the United States if they are engaging in a transaction that involves property that is subject to the jurisdiction of the United States”.

Possible new Syria sanctions

Last week, EU diplomats suggested that some EU Member States, including the UK, France, and Germany, were considering imposing sanctions on several Russian and Syrian people connected to President Assad and involved in the bombardment of Aleppo (see previous blog).  The EU Council has now said that it is aiming to impose further sanctions on Syria, targeting individuals and entities supporting the regime.  The Council’s press release is here.  US Secretary of State John Kerry said on Monday that the USA was also considering new sanctions on the Syrian regime and its supporters.

US eases Cuba sanctions

The USA has further eased its sanctions on Cuba (see previous blog).  The amendments (among other things) remove limits on the value of goods that authorised travellers to Cuba may bring back with them to the US for personal use, including a $100 cap on the value of alcohol and cigars, allow people subject to US jurisdiction to engage in joint medical research with Cuban nationals, and waive the prohibition on foreign vessels docking at US ports within 180 days of visiting Cuba. The US Treasury press release is here.

Possible sanctions for Aleppo bombardment

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OFAC sanctions members of the Altaf Khanani Money Laundering Organisation

OFAC has designated 4 people and 9 entities associated with the Altaf Khanani Money Laundering Organisation (AKMLO), which was itself designated by OFAC in November 2015.  AKMLO is said to engage in third-party money laundering by transferring funds to financial institutions on behalf of drug traffickers and transnational criminal organisations across the globe.  Among those newly designated are several family members of Altaf Khanani and a number of general trading companies, which have acted as payment intermediaries or money transmitters for AKMLO.

The US Treasury’s press release is here, and the details of the listings are here.