The US Treasury has designated Batoul Rida, an official of the Central Bank of Syria, as a Specially Designated National, for acting for and providing support to the government of Syria in its military campaign against the Syrian people.
It has also designated what it describes as a Syria-based front company Sigma Tech Company, and Lebanon-based front companies Shadi for Cars Trading and Denise Company for acting for or on behalf of the Scientific Studies and Research Centre (SSRC). SSRC is a US and EU-sanctioned Syrian government agency involved in the development of non-conventional weapons, with alleged ties to the Syrian chemical weapons program. It was originally listed in June 2005 for being connected to Syria’s weapons of mass destruction proliferation activities.
The designations are made pursuant to Executive Order 13582 and Executive Order 13382 and impose a freeze on all of their assets within US jurisdiction in addition to generally prohibiting US persons from engaging in transactions with them.
In a statement published on 31 March 2015, US Acting under Secretary for Terrorism and Financial Intelligence Adam J Szubin stated that “we are determined to use our financial tools to raise the costs to the Syrian government of its illicit activities”.
The US Treasury also updated the listing of Adib Mayaleh, a senior official of the government of Syria, to record an additional alias.
Today, the EU added Aliaskhab Alibulatovich Kebekov to its list of persons subject to counterterrorism sanctions against Al-Qaida. This is to reflect a United Nations Security Council addition on 23 March 2015. Listed individuals are subject to an EU-wide asset freeze.
The update to the listings is set out in Council Implementing Regulation 2015/532 amending Council Regulation (EC) 881/2002. The corresponding HM Treasury and EU notices are here and here.
The European Union has renewed its counterterrorist sanctions against 10 people and 23 entities, and removed 2 other entities. Listed parties are subject to an EU-wide asset freeze.
The two entities that have been deleted are:
- Al-Takfir and Al-Hijra
- Holy Land Foundation for Relief and Development
These changes are set out in Council Implementing Regulation (EU) 2015/513 implementing Council Regulation (EC) 2580/2001 and Council Decision (CFSP) 2015/521 updating Common Position 2001/931/CFSP and repealing Council Decision 2014/483/CFSP. The corresponding HM Treasury notice is here.
Schlumberger, the world’s largest oil-field services company, has agreed to plead guilty and pay a penalty of $232,708,356 for violating US sanctions by facilitating trade with Iran and Sudan. Under the plea agreement, Schlumberger Oil Holdings Ltd (SOHL), the subsidiary responsible for the violations, will also be subject to a 3-year period of corporate probation during which time it will have to maintain its cessation of operations in Iran and Sudan. In addition, its parent company will be required to hire an independent consultant to review its sanctions policies and compliance procedures.
The US Department of Justice stated that from around early 2004 until June 2010, Schlumberger provided oilfield services to customers in Iran and Sudan through non-US subsidiaries. Further, Schlumberger employees approved and disguised requests from Iran and Sudan for the manufacture of new oilfield drilling tools and the spending of money for certain company purchases. It facilitated trade with Iran and Sudan from offices in Sugar Land, Texas.
Speaking on 25 March 2015, US Assistant Attorney General Carlin said that “Over a period of years, Schlumberger Oilfield Holdings Ltd conducted business with Iran and Sudan from the United States and took steps to disguise those business dealings, thereby wilfully violating the US economic sanctions against those regimes”. US Attorney Machen added that “Even if you don’t directly ship goods from the United States to sanctioned countries, you violate our laws when you facilitate trade with those countries from a US-based office building”
The penalty against SOHL comprises $77,569,452 criminal forfeiture, and a criminal fine of $155,138,904, the largest ever levied in connection with an IEEPA prosecution.
Yesterday, the US Treasury’s Office of Foreign Assets Control (OFAC) published a settlement agreement with PayPal totalling $7,658,300, in settlement of PayPal’s potential civil liability for 486 apparent sanctions violations.
The US Treasury announced that for several years up to and including 2013, “PayPal failed to employ adequate screening technology and procedures to identify the potential involvement of US sanctions targets in transactions” that it processed. Additionally, between 20 October 2009 and 1 April 2013 “PayPal processed 136 transactions totalling $7,091.77 to or from a PayPal account registered to an individual on OFAC’s List of Specially Designated Nationals and Blocked Persons”.
The US Treasury explained that PayPal’s automated interdiction filter was not effectively identifying account holders as potential matches to OFAC’s SDN List and, even when it did, PayPal agents dismissed alerts on six separate occasions after failing to obtain or review documentation corroborating the identity of the individual.
The US Treasury announced yesterday that it has designated 4 people and 5 entities said to be associated with the criminal organisation led by narcotics trafficker Naser Kelmendi as Specially Designated Narcotics Traffickers. The designations are made pursuant to the Foreign Narcotics Kingpin Designation Act. They are:
- Elvis Kelmendi
- Besnik Kelmendi
- Liridon Kelmendi
- Donata Kelmendi
The entities listed are:
- Predstavnistvo Casagrande Export-Import
- Donata Company D.O.O.
- Hotel Casa Grande (Montenegro)
- Hotel Casa Grande (Bosnia and Herzegovina)
- N.P.T.T. Dona-Shell
The entries for Naser Kelmendi were also amended.
Naser Kelmendi was arrested on 6 May 2013 pursuant to an international arrest warrant, and was indicted by the Special Prosecution Office of the Republic of Kosovo on 4 July 2014 on charges of murder and narcotics trafficking.
On 24 March 2015, the US Treasury removed 45 people and entities from its list of Specially Designated Nationals on its Cuba sanctions. Listed people and entities have all of their assets in US jurisdiction frozen and there is a prohibition on engaging in transactions with them.
The US Treasury’s Office of Foreign Assets Control announced that the delistings were intended to remove “out-of-date” names from its list: “While these removals are not related to the recent changes to our Cuba sanctions program and rather reflect OFAC’s consistent effort to review and update its SDN list, these delistings are in line with the President’s Cuba policy” (see previous blog). Many of the entries removed were for people who had died, defunct companies, or sunken ships.
On 21 March 2015, the EU added 3 people and 1 entity to its sanctions against Al-Qaida, removed 4 individuals, and amended the entry for 1 other. This is to reflect changes made by the United Nations Security Council on 19 February, 13 March, and 16 March 2015. Listed individuals and entities are subject to an EU-wide asset freeze.
The additions to the list are:
- Angga Dimas Pershada
- Bambang Sukirno
- Wiji Joko Santoso
- Hilal Ahmar Society Indonesia
The removals from the list are:
- Mustafa Mohamed Fadhil
- Ahmed Mohammed Hamed Ali
- Said Ali Al-Shihri
- Hakimullah Mehsud
The entry for Khalifa Muhammad Turki Al-Subaiy is amended to record 2 additional aliases.
The updates are brought into force by Commission Implementing Regulation (EU) 2015/480 amending Council Regulation (EC) 881/2002.