OFAC has fined American Export Lines (AEL), a US-based international freight forwarding and logistics company, $518,063 for violating US sanctions on Iran. The violations, which AEL did not voluntarily disclose, are said to have occurred when AEL transhipped used and junked cars and parts from the US via Iran to Afghanistan on 140 occasions. AEL’s conduct was aggravated by the fact that its President and co-owner knew and approved of the transhipments via Iran, but mitigated by the fact that none of the shipments appear to have had an end use in that country.
OFAC’s enforcement notice is here.
The US State Department has designated 2 leaders of ISIL, Ahmad Alkhald and Abu Yahya al-Iraqi, as Specially Designated Global Terrorists. Mr Alkhald is said to be an ISIL bomb-maker who served as explosives chief of the terrorist cell that carried out the November 2015 attacks in Paris and the March 2016 attack in Brussels. Mr al-Iraqi is a senior ISIL figure who is responsible for ISIL security in Iraq and Syria, including that of ISIL’s leader Abu Bakr al-Baghdadi. The details of the listings are here.
IPSA International Services, Inc., a US-based risk management firm, has been fined $259,200 by OFAC for violating US sanctions on Iran. The violations, worth $290,784, are said to have occurred when IPSA assisted two countries with their citizenship by investment programmes. Some of the applicants to the programmes were Iranian nationals and, because most of the information about them could not be checked or verified from outside of Iran, IPSA and its subsidiaries engaged subcontractors, who in turn hired third parties, to validate their information. As a result, OFAC found that IPSA had directly imported Iranian-origin services into the United States, or done so indirectly by reviewing, approving, and initiating payments to the providers of the Iranian origin services by its foreign subsidiaries.
The base penalty amount was $720,000 and the maximum penalty available was $18,000,000. In aggravation, OFAC found that IPSA had not voluntarily disclosed the violations, that at least one of its senior management knew or had reason to know of the violations, and that the underlying conduct was not eligible for OFAC authorisation under an existing licence. In mitigation, OFAC said that IPSA had substantially cooperated with its investigation and taken significant remedial measures to prevent further violations from occurring in the future.
China has begun to implement the most recent wave of UN sanctions on North Korea, imposed by a resolution passed on 6 August (see previous blog). Yesterday, its Commerce Ministry authorised the implementation of the new prohibitions on North Korean exports of coal, iron, iron ore, lead, lead ore, and seafood. Cargo already en route to China will be cleared as usual before the deadline for implementing the new sanctions passes on 6 September.
China has yet to begin implementation of other elements of the new sanctions, which include a ban on increasing the total number of work authorisations for North Koreans without approval from the Security Council committee and a ban on the opening of new joint ventures or expansion of existing joint ventures with North Korean firms or people.
The US Department of State has designated the Pakistani militant group Hizbul Mujahideen (HM) as a Foreign Terrorist Organisation and Specially Designated Global Terrorist. Formed in 1989, HM is said to be one of the largest and oldest militant groups operating in the region and has claimed responsibility for several attacks, including the April 2014 explosive attack in Jammu and Kashmir which injured 17 people.
The details of the listing are here.
Iran has banned 2 members of its national football team, including its captain for life, after they played in a match between their Greek club Panionios and Israeli team Maccabi Tel Aviv. Iran has said their participation in the game violated a longstanding unwritten rule that Iranian sportspeople should not compete against their Israeli counterparts.
In 2013, the United States published Iran General Licence F, which authorises US sportspeople to participate in competitions involving Iran.
Iran’s President Hassan Rouhani has said that Iran will restart its nuclear programme “within hours” if the US imposes new sanctions on Iran. Since the JCPOA came into force at the start of 2016, Iran has conducted several ballistic missile tests. The US believes that the tests violate UN sanctions, which prohibit “any activity related to ballistic missiles designed to be capable of delivering nuclear weapons”. Iran has said that any new sanctions breach the JCPOA and that its ballistic missiles are not designed to carry nuclear warheads.
The US designated 14 more Iranian people and entities in July for (among other things) involvement in Iran’s ballistic missile programme (see previous blog).
The US has sanctioned alleged Mexican narcotics kingpin Raul Flores Hernandez and his trafficking network. Among those designated are Mexican professional footballer Rafael Marquez, Mexican singer Julion Alvarez, and 19 other people and 42 entities across a range of industries in the country.
The US Treasury’s press release states that this is the largest single Kingpin Act action against a Mexican drug cartel, and that it follows a multi-year joint investigation involving several US agencies and the government of Mexico. The details of the listings are here.