OFAC has designated Afaq Dubai, an Iraq-based money services business (MSB), as a Specially Designated Global Terrorist pursuant to Executive Order 13224 (US asset freeze) for “moving money for [ISIS]”. The US Treasury press release says “[c]ontrary to what the name may imply, this MSB is located in Iraq and does not have any branches in the United Arab Emirates”. See OFAC Notice.
The UN Security Council has designated 3 vessels – Shang Yuan Bao, New Regent, and Kum Un San 3 – pursuant to para 12 of UNSC Resolution 2321 (2016) and para 6 of UNSC Resolution 2371 (2017), for engaging in illicit North Korea-related ship-to-ship transfers, “likely for oil”. The vessels will now be subject to de-flagging and a UN-wide port ban. See UN press release.
Peters & Peters will be hosting a breakfast seminar on the latest developments in economic sanctions on 6 November 2018 – the day after full ‘snap back’ of US secondary sanctions on Iran.
Anna Bradshaw will chair the event in discussion with leading sanctions practitioners including confirmed speakers Maya Lester QC of Brick Court Chambers and Barbara Linney of Miller & Chevalier in Washington DC.
Discussions will focus on the repercussions of US sanctions policy for EU businesses and the experience of the extended EU Blocking Statute to date. Panellists will also consider the interplay with global anti-money laundering and counter-terrorist financing standards as well as with other US and EU sanctions programmes.
The Law Society – Reading Room
113 Chancery Lane
8:30 am – Registration
9:00 am – Start
10:00 am – Finish
Places are limited for this open invitation event. Please confirm your attendance as soon as possible by emailing firstname.lastname@example.org (indicating any dietary requirements).
Yesterday, the EU extended its ISIL (Da’esh) and Al-Qaida sanctions measures until 31 October 2019. The EU also added Algerian national Hocine Bouguetof to the sanctions list (travel ban, asset freeze, and arms embargo imposed). See Council Decision (CFSP) 2018/1540 and Council Implementing Regulation (EU) 2018/1539.
The EU announced today that it has adopted a new sanctions regime to “address the use and proliferation of chemical weapons”. As a result, the EU will now be able to impose an EU-wide travel ban and/or asset freeze on those “involved in the development and use of chemical weapons anywhere, regardless of their nationality and location”. See Council Decision (CFSP) 2018/1544 and Council Regulation (EU) 2018/1542.
It is reported that Anatoliy Vladimirovich Chepiga and Alexander Mishkin – the two Russian military intelligence officers allegedly involved in the Novichok poisoning of Sergei and Yulia Skripal in Salisbury, UK – will be the first targets sanctioned under the new regime.
Yesterday, the US Financial Crimes Enforcement Network (FinCEN) issued an advisory to help U.S. financial institutions detect and report potentially illicit transactions related to Iran and to help foreign financial institutions “understand the obligations of their U.S. correspondents, to avoid exposure to U.S. sanctions, and to address the Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) risks that Iranian activity poses to the international financial system”.
The US Treasury press release says that following the full re-imposition on 5 November 2018 of sanctions lifted under the Joint Comprehensive Plan of Action (JCPOA), FinCEN “expects that Iranian financial institutions, the Iranian regime, and its officials will increase their efforts to evade U.S. sanctions to fund malign activities and secure hard currency for the Government of Iran. Treasury and the U.S. Government are interested in information related to the Iranian regime’s efforts outlined in this advisory, as well as information pertaining to how the Iranian regime or Iranian entities subject to sanctions, including the CBI, otherwise evade the sanctions and access the U.S. financial system.”
Yesterday, OFSI renewed the terrorist listings of two entities – Ejército de Liberación Nacional (ELN) and Sendero Luminoso (SL) – under the Terrorist Asset-Freezing etc Act 2010 (TAFA).
The OFSI Notice explains that a renewed designation may be appealed to the High Court (or, in Scotland, to the Court of Session) under section 26 of TAFA.