Yesterday, 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 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.
Yesterday, 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).
Iraqi Prime Minister Haider al-Abadi has lifted an international flight ban to its Kurdistan region after Kurdish authorities agreed for the Erbil and Sulaimaniyah airports to come under federal control, reporting to Baghdad’s Ministry of Interior. The ban was imposed in September 2017 as part of a sanctions package in response to the region’s independence referendum.
Last month, the Iraqi Parliament voted to lift sanctions against 4 banks in the Kurdistan region on the basis that the measures “had fulfilled [their] objective” in enforcing federal control over the Kurdish banking system (see previous blog here).
Earlier this week, the Iraqi Parliament voted to lift sanctions against 4 banks in the Kurdistan region (Kurdistan International Bank (KIB), RT Bank, Cihan Bank, and Erbil Bank). Sanctions had been imposed in relation to the region’s September 2017 independence referendum, and consisted of restrictions (by the Central Bank of Iraq) on dollar and foreign currency transfers and sales to the Kurdish-owned banks. In approving the move, Iraqi politicians have stated that the sanctions “had fulfilled [their] objective” by enforcing federal control over the Kurdish banking system. It will now fall to the Iraqi Government to enact the decision.
Turkey’s President Recep Tayyip Erdogan has said that his country is considering imposing sanctions on Kurdish northern Iraq in response to the regional administration’s plans for an independence referendum. Although Turkey has a significant trading relationship with the region, it says that it is opposed to its independence on the basis that it may lead to new conflict in the Middle East. Turkey’s government is expected to make a formal response to the situation on Friday.
The EU has de-listed Iraq-based entities Medical City Establishment and State Company for Drugs and Medical Appliances from its sanctions on Iraq. The changes implement a UN decision to de-list them at the end of last year.