UN removes another Iraqi entity from sanctions list

UN2The UN Security Council has removed the ‘Directorate General of Geological Survey and Mineral Investigation’ from its Iraq sanctions list. As a result, it will no longer be subject to UN asset freezing measures. See UN press release and UK OFSI Notice.

This is the ninth entity to be delisted from the UN’s Iraq sanctions since June 2018 (see our previous blogs).

UN removes 4 state entities from Iraq sanctions

UN4Yesterday, the UN Security Council removed 4 Iraqi state entities from its sanctions list: Iraqi Tobacco State Establishment; Mosul Sugar State Company; State Enterprise for Dairy Products; and State Enterprise for Vegetable Oils. As a result, they will no longer be subject to UN asset freezing measures. UN press release here. These de-listings were implemented by the EU under Commission Implementing Regulation (EU) 2018/1066. UK OFSI Notice here.

Earlier this month, the Council also removed the General Establishment for Grain Trading from its Iraq sanctions list (previous blog), as well as 2 Iraqi insurance companies: Iraqi Life Insurance Company and National Insurance Company (previous blog). These de-listings were implemented by the EU under Commission Implementing Regulation (EU) 2018/979 and Commission Implementing Regulation (EU) 2018/1025 respectively.

UN lifts sanctions on 2 Iraqi insurance companies

UNSCLast week (13 July 2018), the UN Security Council removed 2 entities from its Iraq sanctions list: ‘Iraqi Life Insurance Company’ and ‘National Insurance Company’. As a result, they will no longer be subject to UN asset freezing measures. UN press release here.

EU implements UN de-listing of Iraq’s State Organisation of Grain

EU4Earlier this week, the UN Security Council removed the ‘General Establishment for Grain Trading’ from its Iraq sanctions list (previous blog).

Yesterday, the EU implemented this UN delisting by adopting Commission Implementing Regulation (EU) 2018/979. As a result, the body will no longer be subject to EU asset freezing measures. UK OFSI Notice here.

UN removes Central Bank of Iraq from Iraq sanctions & adds 6 people to Libya sanctions over human trafficking

UN4.jpgYesterday, the UN Security Council removed the Central Bank of Iraq from its Iraq sanctions list (press release) and added 6 individuals to its Libya sanctions list for their involvement in the “illicit trafficking of migrants in Libya” (press release). The 6 individuals are Ermias Ghermay, Fitiwi Abdelrazak, Ahmad Oumar al-Dabbashi, Mus’ab Abu-Qarin, Mohammed Kachlaf, and Abd Al-Rahan al-Milad (all subject to asset freezes and travel bans). UK OFSI Notice here.

On 11 June 2018, the US implemented the UN Libya action, see OFAC Notice and Treasury press release.

On 18 June 2018, the EU  implemented the UN Iraq action, see Commission Implementing Regulation (EU) 2018/875.

US continues Iraq sanctions for 1 year

White House2.jpgOn 22 May 2003, the US adopted Executive Order (E.O.) 13303, which declared a national emergency with respect to Iraq. That E.O. was later amended by (inter alia) E.O. 13315, E.O. 13350 and E.O. 13438, which imposed asset freezes on the “former Iraqi regime, its senior officials and their family members”, as well as those “threatening the peace or stability of Iraq or the Government of Iraq”.

On 18 May 2018, President Donald Trump extended those sanctions for 1 year by continuing the national emergency as declared. White House press release here.

OFAC sanctions Iran’s Central Bank Governor and Iraqi Bank

US Treasury Building.jpgYesterday, OFAC designated an Iraq-based bank (Al-Bilad Islamic Bank) and 4 people as Specially Designated Global Terrorists, pursuant to Executive Order 13224, for “mov[ing] millions of dollars on behalf of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) to Hizballah”. All are now subject to asset freezing measures and secondary sanctions under the Iranian or Hizballah Financial Sanctions Regulations (prohibitions or strict conditions on the opening or maintaining in the US of a correspondent account or a payable-through account by a foreign financial institution). OFAC Notice and Treasury press release.

The 4 designated individuals are Valiollah Seif (Iran’s Central Bank Governor), Ali Tarzali (assistant director of the International Department at the Central Bank of Iran), Aras Habib Kareem (Chairman and Chief Executive of Al-Bilad Islamic Bank), and Muhammad Qasir (Hizballah official).

The designations of Mr Seif and Mr Tarzali do not extend to the Central Bank of Iran.  However, due to President Trump’s decision to cease US participation in the JCPOA, as of 7 August 2018, the US will re-impose sanctions that extend to certain transactions with the Central Bank of Iran, including sanctions on the purchase or acquisition of US dollar banknotes by the Government of Iran. Furthermore, on 5 November 2018, additional sanctions will be re-imposed on persons knowingly engaging in certain significant transactions with the Central Bank of Iran.

Last week, OFAC sanctioned an IRGC-QF-associated currency exchange network procuring millions of dollars through the UAE (previous blog).