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8/27/2010 5:43:06 PM
Topic: Treasury Designates Al-Qai’da Finance Leader

Admin
Posts 393

August 24, 2010
TG-838


Treasury Designates Al-Qai’da Finance Section Leader


WASHINGTON – The U.S. Department of the Treasury today further targeted the financial network of al-Qai'da by designating Muhammad Abdallah Hasan Abu-al-Khayr, a key leader of the terrorist organization's finance section. Al-Khayr was designated pursuant to Executive Order 13224 for acting for or on behalf of al-Qai'da. Executive Order 13224 freezes any assets al-Khayr has under U.S. jurisdiction and prohibits U.S. persons from engaging in any transactions with him. The United Nations 1267 Sanctions Committee took similar action against Al-Khayr today.  



Al-Khayr appears on a 2009 list of 85 persons wanted by the government of Saudi Arabia, in part because of his role as an al-Qai'da financial facilitator. He has transferred hundreds of thousands of dollars for a specific terrorist attack against U.S. interests.  Al-Khayr also acts for al-Qai'da in a leadership role on the media committee, and has on at least one occasion recruited a member for al-Qai'da. His relationship with al-Qai'da began with military training the terrorist group provided him in the mid-1990s. Al-Khayr is a son-in-law of Usama bin Laden and has also provided services to bin Laden as a bodyguard.



"After the death in May of Mustafa Abu al-Yazid, who essentially served as al-Qai'da's chief financial officer, we will continue to work with our allies to target those like al-Khayr who could step into al-Yazid's shoes," said Under Secretary for Terrorism and Financial Intelligence Stuart Levey.  "Today's designation of al-Khayr by the United States and the United Nations will help to ensure that that al-Qai'da remains in severe financial straits."



Identifying Information:



MUHAMMAD ABDALLAH HASAN ABU-AL-KHAYR


AKA:              Abdallah al-Halabi


AKA:              'Abdallah al-Halabi al-Madani


AKA:              Abdallah al-Makki


AKA:              Abdallah el Halabi


AKA:              Abdullah al-Halabi


AKA:              Abu 'Abdallah al-Halabi


AKA:              Abu Abdallah al-Madani


AKA:              Mohammed Abdullah Hassan Abul-Khair


AKA:              Muhammad Bin- 'Abdullah Bin-Hamd Abu-al-Khayr


AKA:              Muhannad al-Jaddawi


POB:               Al-Madinah al-Munawwarah. Saudi Arabia


DOB:              June 19, 1975


Alt. DOB:       June 18, 1975


Passport:          Saudi A741097


                        Issued: November 14, 1995; Expired: September 19, 2000


National Identification Number:  Saudi, 1006010555



8/26/2010 4:13:38 PM
Topic: Link to Cayman Islands Monetary Authority

Admin
Posts 393

Link to Cayman Islands Monetary Authority


The Cayman Islands Monetary Authority has become aware of entities with websites that have given their contact addresses as being in the Cayman Islands.  The entities listed in the document below are not licensed or registered to carry on activities regulated by the Cayman Islands Monetary Authority.  Our inquiries also reveal that they are also not registered with the Cayman Islands Companies Registry.  


The Authority would encourage people receiving any form of approach from these purported entities not to respond to them in any way


Link to site: http://www.cimoney.com.ky/enforcement/info_alerts.aspx?id=168


edited by Admin on 8/26/2010

8/26/2010 4:12:08 PM
Topic: Entities Not Authorized by the Cayman Islands

Admin
Posts 393

















TO:


CHIEF EXECUTIVE OFFICER (also of interest to Security Officer)


SUBJECT:


Entities Not Authorized by the Cayman Islands Monetary Authority


Summary:


The Cayman Islands Monetary Authority has revised its list of entities that provide a Cayman Islands mailing address, but are neither registered nor licensed to conduct business activities regulated by the Cayman Islands Monetary Authority.


 


On July 14, 2010, the Cayman Islands Monetary Authority (CIMA) published the attached list of financial entities that have Cayman Island addresses, but are neither registered nor licensed to undertake activities regulated by the CIMA. The notice also states that none of the entities are registered with the Cayman Islands Companies Registry.


These entities or persons representing them may be operating in the Cayman Islands, offering banking or other financial services to individuals, businesses or financial institutions located in the United States. They may be violating provisions of the Banks and Trust Companies Law (revised 2003) or other regulations issued by the Cayman Islands government. These entities may also be conducting or facilitating unauthorized financial transactions in the United States. Any proposed transactions involving these entities should be viewed with extreme caution.


Any information about these entities may be forwarded to the FDIC's Cyber Fraud and Financial Crimes Section, 550 17th Street, N.W., Room F-3054, Washington, D.C. 20429 or transmitted electronically to alert@fdic.gov.


For your reference, FDIC Special Alerts may be accessed from the FDIC's website at www.fdic.gov/news/news/SpecialAlert/2010/index.html. To learn how to automatically receive FDIC Special Alerts through e-mail, please visit www.fdic.gov/about/subscriptions/index.html. This Special Alert replaces SA-40-2010.














 


Sandra L. Thompson


 


Director
Division of Supervision and Consumer Protection


Attachment: May be a accessed through http://www.cimoney.com.ky/enforcement/info_alerts.aspx?id=168


Distribution: FDIC-Supervised Banks (Commercial and Savings)


NOTE: Paper copies of FDIC Special Alerts may be obtained through the FDIC's Public Information Center, 1-877-275-3342 or 703-562-2200.





8/24/2010 2:27:18 PM
Topic: SDN List Addition 8/24/10

Admin
Posts 393

The following individuals have been added to OFAC's SDN list:

ABU-AL-KHAYR, Muhammad Abdallah Hasan (a.k.a. ABU-AL-KHAYR, Muhammad Bin-'Abdullah Bin-Hamd; a.k.a. ABUL-KHAIR, Mohammed Abdullah Hassan; a.k.a. AL-HALABI, Abdallah; a.k.a. AL-HALABI, Abdullah; a.k.a. AL-HALABI, Abu 'Abdallah; a.k.a. AL-JADDAWI, Muhannad; a.k.a. AL-MADANI, 'Abdallah al-Halabi; a.k.a. AL-MADANI, Abu Abdallah; a.k.a. AL-MAKKI, Abdallah; a.k.a. EL HALABI, Abdallah); DOB 19 Jun 1975; alt. DOB 18 Jun 1975; POB Al-Madinah al-Munawwarah, (Medina) Saudi Arabia; National ID No. 1006010555 (Saudi Arabia); Passport A741097 (Saudi Arabia) issued 14 Nov 1995 expires 19 Sep 2000 (individual) [SDGT]


8/20/2010 6:20:54 PM
Topic: Dodd Frank Reform Regulation

Admin
Posts 393

See the attached provided by Accume Partners. This is an excellent handout that will show you what you should be doing now while you are waiting for the regulations to be issued. Thank you to our Florida Chapter leader, Wilfredo for providing to our members. 



8/20/2010 6:17:15 PM
Topic: Request For SAR Supporting Documents-How to Handle

Admin
Posts 393

Question: Our financial institution has received a request over the phone from a special agent of Homeland Security for any additional information on a SAR we have filed.  I know that we need to identify the individual and his credentials; however, do we need anything in writing requesting the additional information? 


 


Answer: No. It is a good business practice (not required by the law) to ask for the request for the supporting documentation to be in writing (an email is acceptable). When the agent arrives on the scene, request their official ID to verify they are an authorized law enforcement officer. You may consider having them sign & date a pre-printed statement that they obtained the docs.      


Please refer to the following link from Page 44 of the SAR Activity Review link which explains this process. Make sure that they are in your written procedures.


http://www.fincen.gov/news_room/rp/files/sar_tti_09.pdf


FFIEC BSA/AML Exam Manual 


SAR Record Retention and Supporting Documentation


Banks must retain copies of SARs and supporting documentation for five years from the date of filing the SAR. Additionally, banks must provide all documentation supporting the filing of a SAR upon request by FinCEN or an appropriate law enforcement or federal banking agency. "Supporting documentation" refers to all documents or records that assisted a bank in making the determination that certain activity required a SAR filing. No legal process is required for disclosure of supporting documentation to FinCEN or an appropriate law enforcement or federal banking agency.72


 


 


 


 


 



8/20/2010 6:03:49 PM
Topic: SDN List Updated 8/16/2010 IRAN Sanctions

Admin
Posts 393

Based upon the Iran Sanctions:


The following changes have been made to OFAC's SDN list:


ARIAN BANK (a.k.a. ARYAN BANK), House 2, Street Number 13, Wazir Akbar Khan, Kabul, Afghanistan [NPWMD] [IFSR]


BANCO INTERNACIONAL DE DESARROLLO, C.A., Urb. El Rosal, Avenida Francisco de Miranda, Edificio Dozsa, Piso 8, Caracas C.P. 1060, Venezuela; RIF # J294640109 (Venezuela); SWIFT/BIC IDUNVECA; Banco Internacional de Desarrollo, C.A. is a separate and distinct entity from Banco Interamericano de Desarrollo, known in English as the Inter-American Development Bank (IADB), and from Banco Desarrollo Economico y Social De Venezuela (BANDES), an entity owned by the Government of Venezuela [NPWMD] [IFSR]


BANK KARGOSHAEE (a.k.a. KARGOSA'I BANK), 587 Mohammadiye Square, Mowlavi St., Tehran 11986, Iran [NPWMD] [IFSR]


BANK MELLI IRAN ZAO, Number 9/1, Ulitsa Mashkova, Moscow 103064, Russia [NPWMD] [IFSR]


BANK SEPAH INTERNATIONAL PLC, 5-7 Eastcheap, London EC3M 1JT, United Kingdom [NPWMD] [IFSR]


MELLAT BANK SB CJSC (a.k.a. "MELLAT BANK DB AOZT"), P.O. Box 24, Yerevan 0010, Armenia [NPWMD] [IFSR]


MELLI BANK PLC, 1 London Wall, London EC2Y 5EA, United Kingdom [NPWMD] [IFSR]


AHMADIAN, Ali Akbar (a.k.a. AHMADIYAN, Ali Akbar); DOB circa 1961; POB Kerman, Iran; citizen Iran; nationality Iran (individual) [NPWMD] -to- AHMADIAN, Ali Akbar (a.k.a. AHMADIYAN, Ali Akbar); DOB circa 1961; POB Kerman, Iran; citizen Iran; nationality Iran (individual) |[NPWMD] [IRGC]|


ALLAHDAD, Hushang (a.k.a. ALLAHDADI, Hushang; a.k.a. GOLZARI, Sa'id); Passport A0022791; alt. Passport 08550695 (individual) [SDGT] -to- ALLAHDAD, Hushang (a.k.a. ALLAHDADI, Hushang; a.k.a. GOLZARI, Sa'id); Passport A0022791; alt. Passport 08550695 (individual) |[IRGC] [SDGT]|


BANK MELLAT, Head Office Bldg, 327 Taleghani Ave, Tehran 15817, Iran; 327 Forsat and Taleghani Avenue, Tehran 15817, Iran; PO Box 375010, Amiryan Str #6, P/N-24, Yerevan, Armenia; Keumkang Tower - 13th & 14th Floor, 889-13 Daechi-Dong, Gangnam-Ku, Seoul 135-280, Korea, South; PO Box 79106425, Ziya Gokalp Bulvari No 12, Kizilay, Ankara, Ankara, Turkey; Cumhuriyet Bulvari No 88/A, PK 7103521, Konak, Izmir, Turkey; Buyukdere Cad, Cicek Sokak No 1 - 1 Levent, Levent, Istanbul, Turkey; all offices worldwide [IRAN] [NPWMD] -to- BANK MELLAT, Head Office Bldg, 327 Taleghani Ave, Tehran 15817, Iran; 327 Forsat and Taleghani Avenue, Tehran 15817, Iran; PO Box 375010, Amiryan Str #6, P/N-24, Yerevan, Armenia; Keumkang Tower - 13th & 14th Floor, 889-13 Daechi-Dong, Gangnam-Ku, Seoul 135-280, Korea, South; PO Box 79106425, Ziya Gokalp Bulvari No 12, Kizilay, Ankara, Ankara, Turkey; Cumhuriyet Bulvari No 88/A, PK 7103521, Konak, Izmir, Turkey; Buyukdere Cad, Cicek Sokak No 1 - 1 Levent, Levent, Istanbul, Turkey; all offices worldwide |[IRAN] [NPWMD] [IFSR]|


BANK MELLI IRAN (a.k.a. BANK MELLI; a.k.a. NATIONAL BANK OF IRAN), PO Box 11365-171, Ferdowsi Avenue, Tehran, Iran; 43 Avenue Montaigne, Paris 75008, France; Room 704-6, Wheelock Hse, 20 Pedder St, Central, Hong Kong; Bank Melli Iran Bldg, 111 St 24, 929 Arasat, Baghdad, Iraq; PO Box 2643, Ruwi, Muscat 112, Oman; PO Box 2656, Liva Street, Abu Dhabi, United Arab Emirates; PO Box 248, Hamad Bin Abdulla St, Fujairah, United Arab Emirates; PO Box 1888, Clock Tower, Industrial Rd, Al Ain Club Bldg, Al Ain, Abu Dhabi, United Arab Emirates; PO Box 1894, Baniyas St, Deira, Dubai City, United Arab Emirates; PO Box 5270, Oman Street Al Nakheel, Ras Al-Khaimah, United Arab Emirates; PO Box 459, Al Borj St, Sharjah, United Arab Emirates; PO Box 3093, Ahmed Seddiqui Bldg, Khalid Bin El-Walid St, Bur-Dubai, Dubai City 3093, United Arab Emirates; PO Box 1894, Al Wasl Rd, Jumeirah, Dubai, United Arab Emirates; Postfach 112 129, Holzbruecke 2, D-20459, Hamburg, Germany; Nobel Ave. 14, Baku, Azerbaijan; Unit 1703-4, 17th Floor, Hong Kong Club Building, 3 A Chater Road Central, Hong Kong; all offices worldwide [IRAN] [NPWMD] -to- BANK MELLI IRAN (a.k.a. BANK MELLI; a.k.a. NATIONAL BANK OF IRAN), PO Box 11365-171, Ferdowsi Avenue, Tehran, Iran; 43 Avenue Montaigne, Paris 75008, France; Room 704-6, Wheelock Hse, 20 Pedder St, Central, Hong Kong; Bank Melli Iran Bldg, 111 St 24, 929 Arasat, Baghdad, Iraq; PO Box 2643, Ruwi, Muscat 112, Oman; PO Box 2656, Liva Street, Abu Dhabi, United Arab Emirates; PO Box 248, Hamad Bin Abdulla St, Fujairah, United Arab Emirates; PO Box 1888, Clock Tower, Industrial Rd, Al Ain Club Bldg, Al Ain, Abu Dhabi, United Arab Emirates; PO Box 1894, Baniyas St, Deira, Dubai City, United Arab Emirates; PO Box 5270, Oman Street Al Nakheel, Ras Al-Khaimah, United Arab Emirates; PO Box 459, Al Borj St, Sharjah, United Arab Emirates; PO Box 3093, Ahmed Seddiqui Bldg, Khalid Bin El-Walid St, Bur-Dubai, Dubai City 3093, United Arab Emirates; PO Box 1894, Al Wasl Rd, Jumeirah, Dubai, United Arab Emirates; Postfach 112 129, Holzbruecke 2, D-20459, Hamburg, Germany; Nobel Ave. 14, Baku, Azerbaijan; Unit 1703-4, 17th Floor, Hong Kong Club Building, 3 A Chater Road Central, Hong Kong; all offices worldwide |[IRAN] [NPWMD] [IFSR]|


BANK SADERAT IRAN (a.k.a. IRAN EXPORT BANK), Ground Floor Business Room, Building Banke Khoon Road, Harat, Afghanistan; No. 56, Opposite of Security Department, Toraboz Khan Str., Kabul, Afghanistan; 5 Lothbury, London EC2R 7HD, United Kingdom; Postfach 112227, Deichstrasse 11, 20459, Hamburg, Germany; PO Box 4308, 25-29 Venizelou St, Athens, Attica GR 105 64, Greece; PO Box 15745-631, Bank Saderat Tower, 43 Somayeh Avenue, Tehran, Iran; 16 rue de la Paix, Paris 75002, France; Postfach 160151, Friedenstr 4, D-60311, Frankfurt am Main, Germany; 3rd Floor, Aliktisad Bldg, Ras El Ein Street Baalbak, Baalbak, Lebanon; Saida Branch, Sida Riad Elsoleh St, Martyrs Sq, Saida, Lebanon; Borj Albarajneh Branch - 20 Alholom Bldg, Sahat Mreijeh, Kafaat St, Beirut, Lebanon; 1st Floor, Alrose Bldg, Verdun - Rashid Karame St, Beirut, Lebanon; PO Box 5126, Beirut, Lebanon; 3rd Floor, Mteco Centre, Mar Elias, Facing Al Hellow Barrak, POB 5126, Beirut, Lebanon; Alghobeiri Branch - Aljawhara Bldg, Ghobeiry Blvd, Beirut, Lebanon; PO Box 1269, Muscat 112, Oman; PO Box 4425, Salwa Rd, Doha, Qatar; PO Box 2256, Doha, Qatar; 2nd Floor, No 181 Makhtoomgholi Ave, Ashgabat, Turkmenistan; PO Box 700, Abu Dhabi, United Arab Emirates; PO Box 16, Liwara Street, Ajman, United Arab Emirates; PO Box 1140, Al-Am Road, Al-Ein, Al Ain, Abu Dhabi, United Arab Emirates; Bur Dubai, Khaled Bin Al Walid St, Dubai City, United Arab Emirates; Sheikh Zayed Rd, Dubai City, United Arab Emirates; PO Box 4182, Almaktoum Rd, Dubai City, United Arab Emirates; PO Box 4182, Murshid Bazar Branch, Dubai City, United Arab Emirates; PO Box 316, Bank Saderat Bldg, Alaroda St, Borj Ave, Sharjah, United Arab Emirates; all offices worldwide [IRAN] [SDGT] -to- BANK SADERAT IRAN (a.k.a. IRAN EXPORT BANK), Ground Floor Business Room, Building Banke Khoon Road, Harat, Afghanistan; No. 56, Opposite of Security Department, Toraboz Khan Str., Kabul, Afghanistan; 5 Lothbury, London EC2R 7HD, United Kingdom; Postfach 112227, Deichstrasse 11, 20459, Hamburg, Germany; PO Box 4308, 25-29 Venizelou St, Athens, Attica GR 105 64, Greece; PO Box 15745-631, Bank Saderat Tower, 43 Somayeh Avenue, Tehran, Iran; 16 rue de la Paix, Paris 75002, France; Postfach 160151, Friedenstr 4, D-60311, Frankfurt am Main, Germany; 3rd Floor, Aliktisad Bldg, Ras El Ein Street Baalbak, Baalbak, Lebanon; Saida Branch, Sida Riad Elsoleh St, Martyrs Sq, Saida, Lebanon; Borj Albarajneh Branch - 20 Alholom Bldg, Sahat Mreijeh, Kafaat St, Beirut, Lebanon; 1st Floor, Alrose Bldg, Verdun - Rashid Karame St, Beirut, Lebanon; PO Box 5126, Beirut, Lebanon; 3rd Floor, Mteco Centre, Mar Elias, Facing Al Hellow Barrak, POB 5126, Beirut, Lebanon; Alghobeiri Branch - Aljawhara Bldg, Ghobeiry Blvd, Beirut, Lebanon; PO Box 1269, Muscat 112, Oman; PO Box 4425, Salwa Rd, Doha, Qatar; PO Box 2256, Doha, Qatar; 2nd Floor, No 181 Makhtoomgholi Ave, Ashgabat, Turkmenistan; PO Box 700, Abu Dhabi, United Arab Emirates; PO Box 16, Liwara Street, Ajman, United Arab Emirates; PO Box 1140, Al-Am Road, Al-Ein, Al Ain, Abu Dhabi, United Arab Emirates; Bur Dubai, Khaled Bin Al Walid St, Dubai City, United Arab Emirates; Sheikh Zayed Rd, Dubai City, United Arab Emirates; PO Box 4182, Almaktoum Rd, Dubai City, United Arab Emirates; PO Box 4182, Murshid Bazar Branch, Dubai City, United Arab Emirates; PO Box 316, Bank Saderat Bldg, Alaroda St, Borj Ave, Sharjah, United Arab Emirates; all offices worldwide |[SDGT] [IRAN] [IFSR]|


BANK SEPAH, Imam Khomeini Square, Tehran 1136953412, Iran; 64 Rue de Miromesnil, Paris 75008, France; Hafenstrasse 54, D-60327, Frankfurt am Main, Germany; Via Barberini 50, Rome, RM 00187, Italy; 17 Place Vendome, Paris 75008, France; all offices worldwide [IRAN] [NPWMD] -to- BANK SEPAH, Imam Khomeini Square, Tehran 1136953412, Iran; 64 Rue de Miromesnil, Paris 75008, France; Hafenstrasse 54, D-60327, Frankfurt am Main, Germany; Via Barberini 50, Rome, RM 00187, Italy; 17 Place Vendome, Paris 75008, France; all offices worldwide |[NPWMD] [IRAN] [IFSR]|


EXPORT DEVELOPMENT BANK OF IRAN (a.k.a. BANK TOSEH SADERAT IRAN; a.k.a. BANK TOWSEEH SADERAT IRAN; a.k.a. BANK TOWSEH SADERAT IRAN; a.k.a. EDBI), Export Development Building, Next to the 15th Alley, Bokharest Street, Argentina Square, Tehran, Iran; Tose'e Tower, Corner of 15th St., Ahmed Qasir Ave., Argentine Square, Tehran, Iran; No. 129, 21's Khaled Eslamboli, No. 1 Building, Tehran, Iran; No. 26, Tosee Tower, Arzhantine Square, P.O. Box 15875-5964, Tehran 15139, Iran; No. 4, Gandi Ave., Tehran 1516747913, Iran; Registration ID 86936 (Iran) issued 10 Jul 1991; all offices worldwide [IRAN] [NPWMD] -to- EXPORT DEVELOPMENT BANK OF IRAN (a.k.a. BANK TOSEH SADERAT IRAN; a.k.a. BANK TOWSEEH SADERAT IRAN; a.k.a. BANK TOWSEH SADERAT IRAN; a.k.a. EDBI), Export Development Building, Next to the 15th Alley, Bokharest Street, Argentina Square, Tehran, Iran; Tose'e Tower, Corner of 15th St., Ahmed Qasir Ave., Argentine Square, Tehran, Iran; No. 129, 21's Khaled Eslamboli, No. 1 Building, Tehran, Iran; No. 26, Tosee Tower, Arzhantine Square, P.O. Box 15875-5964, Tehran 15139, Iran; No. 4, Gandi Ave., Tehran 1516747913, Iran; Registration ID 86936 (Iran) issued 10 Jul 1991; all offices worldwide |[IRAN] [IFSR] [NPWMD]|


FATER ENGINEERING INSTITUTE (a.k.a. FAATER INSTITUTE; a.k.a. FATER ENGINEERING COMPANY; a.k.a. GHARARGAH GHAEM FAATER INSTITUTE), No. 25, Valiasr Jonoobi, Azizi Street, Azadi Sq. NE, Tehran, Iran [NPWMD] -to- FATER ENGINEERING INSTITUTE (a.k.a. FAATER INSTITUTE; a.k.a. FATER ENGINEERING COMPANY; a.k.a. GHARARGAH GHAEM FAATER INSTITUTE), No. 25, Valiasr Jonoobi, Azizi Street, Azadi Sq. NE, Tehran, Iran |[NPWMD] [IRGC]|


FIRST EAST EXPORT BANK, P.L.C., Unit Level 10 (B1) Main Office Tower, Financial Park Labuan, Jalan Merdeka 87000 WP, Labuan, Malaysia; Business Registration Document # LL06889 (Malaysia) [NPWMD] -to- FIRST EAST EXPORT BANK, P.L.C., Unit Level 10 (B1) Main Office Tower, Financial Park Labuan, Jalan Merdeka 87000 WP, Labuan, Malaysia; Business Registration Document # LL06889 (Malaysia) |[NPWMD] [IFSR]|


FORUZANDEH, Ahmed (a.k.a. FAYRUZI, Ahmad; a.k.a. FOROOZANDEH, Ahmad; a.k.a. FORUZANDEH, Ahmad; a.k.a. FRUZANDAH, Ahmad; a.k.a. "ABU AHMAD ISHAB"; a.k.a. "ABU SHAHAB"; a.k.a. "JAFARI"), Qods Force Central Headquarters, Former U.S. Embassy Compound, Tehran, Iran; DOB circa 1960; alt. DOB circa 1963; alt. DOB circa 1962; alt. DOB circa 1961; alt. DOB circa 1959; alt. DOB circa 1958; alt. DOB circa 1955; alt. DOB 1957; POB Kermanshah, Iran; Brigadier General, Commanding Officer of the Iranian Islamic Revolutionary Guard Corps-Qods Force Ramazan Corps; Deputy Commander of the Ramazan Headquarters; Chief of Staff of the Iraq Crisis Staff (individual) [IRAQ3] -to- FORUZANDEH, Ahmed (a.k.a. FAYRUZI, Ahmad; a.k.a. FOROOZANDEH, Ahmad; a.k.a. FORUZANDEH, Ahmad; a.k.a. FRUZANDAH, Ahmad; a.k.a. "ABU AHMAD ISHAB"; a.k.a. "ABU SHAHAB"; a.k.a. "JAFARI"), |Qods Force Central Headquarters, Former U.S. Embassy Compound, Tehran, Iran; DOB circa 1960; alt. DOB 1957; alt. DOB circa 1955; alt. DOB circa 1958; alt. DOB circa 1959; alt. DOB circa 1961; alt. DOB circa 1962; alt. DOB circa 1963; POB Kermanshah, Iran; Brigadier General, Commanding Officer of the Iranian Islamic Revolutionary Guard Corps-Qods Force Ramazan Corps; Deputy Commander of the Ramazan Headquarters; Chief of Staff of the Iraq Crisis Staff| (individual) |[IRAQ3] [IRGC]|


FUTURE BANK B.S.C., Block 304, City Centre Building, Building 199, Government Avenue, Road 383, Manama, Bahrain; P.O. Box 785, City Centre Building, Government Avenue, Manama, Bahrain; Business Registration Document # 54514-1 (Bahrain) expires 9 Jun 2009; Trade License No. 13388 (Bahrain); All branches worldwide [NPWMD] -to- FUTURE BANK B.S.C., |P.O. Box 785, City Centre Building, Government Avenue, Manama, Bahrain; Block 304, City Centre Building, Building 199, Government Avenue, Road 383, Manama, Bahrain; Business Registration Document # 54514-1 (Bahrain) expires 9 Jun 2009; Trade License No. 13388 (Bahrain); All branches worldwide| |[NPWMD] [IFSR]|


GHARARGAHE SAZANDEGI GHAEM (a.k.a. GHARARGAH GHAEM), No. 25, Valiasr St., Azadi Sq., Tehran, Iran [NPWMD] -to- GHARARGAHE SAZANDEGI GHAEM (a.k.a. GHARARGAH GHAEM), No. 25, Valiasr St., Azadi Sq., Tehran, Iran |[NPWMD] [IRGC]|


GHORB KARBALA (a.k.a. GHARARGAH KARBALA; a.k.a. GHARARGAH SAZANDEGI KARBALA-MOASSESEH TAHA), No. 2 Firouzeh Alley, Shahid Hadjipour St., Resalat Highway, Tehran, Iran [NPWMD] -to- GHORB KARBALA (a.k.a. GHARARGAH KARBALA; a.k.a. GHARARGAH SAZANDEGI KARBALA-MOASSESEH TAHA), No. 2 Firouzeh Alley, Shahid Hadjipour St., Resalat Highway, Tehran, Iran |[NPWMD] [IRGC]|


GHORB NOOH, P.O. Box 16765-3476, Tehran, Iran [NPWMD] -to- GHORB NOOH, P.O. Box 16765-3476, Tehran, Iran |[NPWMD] [IRGC]|


HARA COMPANY (a.k.a. HARA INSTITUTE), Tehran, Iran [NPWMD] -to- HARA COMPANY (a.k.a. HARA INSTITUTE), Tehran, Iran |[NPWMD] [IRGC]|


HEJAZI, Mohammad; DOB circa 1959; citizen Iran; nationality Iran (individual) [NPWMD] -to- HEJAZI, Mohammad; DOB circa 1959; citizen Iran; nationality Iran (individual) |[NPWMD] [IRGC]|


IMENSAZEN CONSULTANT ENGINEERS INSTITUTE, No. 5/1, Niroo Alley, Padegan-e-Valiasr Street, Sepah Square, Tehran, Iran [NPWMD] -to- IMENSAZEN CONSULTANT ENGINEERS INSTITUTE, No. 5/1, Niroo Alley, Padegan-e-Valiasr Street, Sepah Square, Tehran, Iran |[NPWMD] [IRGC]|


ISLAMIC REVOLUTIONARY GUARD CORPS (a.k.a. AGIR; a.k.a. IRANIAN REVOLUTIONARY GUARD CORPS; a.k.a. IRG; a.k.a. IRGC; a.k.a. ISLAMIC REVOLUTIONARY CORPS; a.k.a. PASDARAN; a.k.a. PASDARAN-E ENGHELAB-E ISLAMI; a.k.a. PASDARAN-E INQILAB; a.k.a. REVOLUTIONARY GUARD; a.k.a. REVOLUTIONARY GUARDS; a.k.a. SEPAH; a.k.a. SEPAH PASDARAN; a.k.a. SEPAH-E PASDARAN-E ENQELAB-E ESLAMI; a.k.a. THE ARMY OF THE GUARDIANS OF THE ISLAMIC REVOLUTION; a.k.a. THE IRANIAN REVOLUTIONARY GUARDS), Tehran, Iran [NPWMD] -to- ISLAMIC REVOLUTIONARY GUARD CORPS (a.k.a. AGIR; a.k.a. IRANIAN REVOLUTIONARY GUARD CORPS; a.k.a. IRG; a.k.a. IRGC; a.k.a. ISLAMIC REVOLUTIONARY CORPS; a.k.a. PASDARAN; a.k.a. PASDARAN-E ENGHELAB-E ISLAMI; a.k.a. PASDARAN-E INQILAB; a.k.a. REVOLUTIONARY GUARD; a.k.a. REVOLUTIONARY GUARDS; a.k.a. SEPAH; a.k.a. SEPAH PASDARAN; a.k.a. SEPAH-E PASDARAN-E ENQELAB-E ESLAMI; a.k.a. THE ARMY OF THE GUARDIANS OF THE ISLAMIC REVOLUTION; a.k.a. THE IRANIAN REVOLUTIONARY GUARDS), Tehran, Iran |[NPWMD] [IRGC]|


ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE (a.k.a. PASDARAN-E ENGHELAB-E ISLAMI (PASDARAN); a.k.a. SEPAH-E QODS (JERUSALEM FORCE)) [SDGT] -to- ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE (a.k.a. PASDARAN-E ENGHELAB-E ISLAMI (PASDARAN); a.k.a. SEPAH-E QODS (JERUSALEM FORCE)) |[SDGT] [IRGC]|


ISLAMIC REVOLUTIONARY GUARD CORPS AIR FORCE (a.k.a. IRGC AIR FORCE; a.k.a. SEPAH PASDARAN AIR FORCE), Tehran, Iran [NPWMD] -to- ISLAMIC REVOLUTIONARY GUARD CORPS AIR FORCE (a.k.a. IRGC AIR FORCE; a.k.a. SEPAH PASDARAN AIR FORCE), Tehran, Iran |[IRGC] [NPWMD]|


ISLAMIC REVOLUTIONARY GUARD CORPS MISSILE COMMAND (a.k.a. IRGC MISSILE COMMAND), Tehran, Iran [NPWMD] -to- ISLAMIC REVOLUTIONARY GUARD CORPS MISSILE COMMAND (a.k.a. IRGC MISSILE COMMAND), Tehran, Iran |[IRGC] [NPWMD]|


JAFARI, Mohammad Ali (a.k.a. JAFARI-NAJAFABADI, Mohammad Ali), c/o IRGC, Tehran, Iran; DOB 1957; POB Yazd, Iran; nationality Iran; Commander-in-Chief, IRGC (individual) [NPWMD] -to- JAFARI, Mohammad Ali (a.k.a. JAFARI-NAJAFABADI, Mohammad Ali), c/o IRGC, Tehran, Iran; DOB 1957; POB Yazd, Iran; nationality Iran; Commander-in-Chief, IRGC (individual) |[NPWMD] [IRGC]|


KHATAM OL ANBIA GHARARGAH SAZANDEGI NOOH (a.k.a. GHORB KHATAM; a.k.a. KHATAM AL-ANBYA; a.k.a. KHATAM OL AMBIA), No. 221, Phase 4, North Falamak-Zarafshan Intersection, Shahrak-E-Ghods, Tehran 14678, Iran [NPWMD] -to- KHATAM OL ANBIA GHARARGAH SAZANDEGI NOOH (a.k.a. GHORB KHATAM; a.k.a. KHATAM AL-ANBYA; a.k.a. KHATAM OL AMBIA), No. 221, Phase 4, North Falamak-Zarafshan Intersection, Shahrak-E-Ghods, Tehran 14678, Iran |[NPWMD] [IRGC]|


MORTEZAVI, Hasan (a.k.a. MORTEZAVI, Ali Hassan; a.k.a. MORTEZAVI, Majid; a.k.a. MORTEZAVI, Majid Mirali; a.k.a. "ALI, Hassan"); DOB 28 Apr 1961; POB Ghazvin, Iran; citizen Iran; Passport 7572775 (Iran) (individual) [SDGT] -to- MORTEZAVI, Hasan (a.k.a. MORTEZAVI, Ali Hassan; a.k.a. MORTEZAVI, Majid; a.k.a. MORTEZAVI, Majid Mirali; a.k.a. "ALI, Hassan"); DOB 28 Apr 1961; POB Ghazvin, Iran; citizen Iran; Passport 7572775 (Iran) (individual) |[SDGT] [IRGC]|


MUSAVI, Hossein; DOB 23 Oct 1960; POB Neishabour, Iran; nationality Iran; Passport A0016662 (Iran) issued 29 Oct 2002 (individual) [SDGT] -to- MUSAVI, Hossein; DOB 23 Oct 1960; POB Neishabour, Iran; nationality Iran; Passport A0016662 (Iran) issued 29 Oct 2002 (individual) |[SDGT] [IRGC]|


NAQDI, Mohammad Reza; DOB circa 1952; alt. DOB circa Mar 1961; alt. DOB circa Apr 1961; POB Najaf, Iran; alt. POB Tehran, Iran; Brigadier General and Commander of the IRGC Basij Resistance Force (individual) [NPWMD] -to- NAQDI, Mohammad Reza; DOB circa 1952; alt. DOB circa Mar 1961; alt. DOB circa Apr 1961; POB Najaf, Iran; alt. POB Tehran, Iran; Brigadier General and Commander of the IRGC Basij Resistance Force (individual) |[IRGC] [NPWMD]|


OMRAN SAHEL, Tehran, Iran [NPWMD] -to- OMRAN SAHEL, Tehran, Iran |[NPWMD] [IRGC]|


ORIENTAL OIL KISH, Dubai, United Arab Emirates; Second Floor, 96/98 East Atefi St., Africa Blvd., Tehran, Iran [NPWMD] -to- ORIENTAL OIL KISH, |Second Floor, 96/98 East Atefi St., Africa Blvd., Tehran, Iran; Dubai, United Arab Emirates| |[NPWMD] [IRGC]|


PERSIA INTERNATIONAL BANK PLC, 6 Lothbury, London EC2R 7HH, United Kingdom; Dubai International Financial Centre, Level 4, The Gate Building, P.O. Box 119871, Dubai, United Arab Emirates; all offices worldwide [NPWMD] -to- PERSIA INTERNATIONAL BANK PLC, |Dubai International Financial Centre, Level 4, The Gate Building, P.O. Box 119871, Dubai, United Arab Emirates; 6 Lothbury, London EC2R 7HH, United Kingdom; all offices worldwide| |[NPWMD] [IFSR]|


POST BANK OF IRAN, 237 Motahari Avenue, Tehran 1587618118, Iran [NPWMD] -to- POST BANK OF IRAN, 237 Motahari Avenue, Tehran 1587618118, Iran |[NPWMD] [IFSR]|


QASEMI, Rostam (a.k.a. GHASEMI MOHAMMADALI, ROSTAM), Iran; citizen Iran; nationality Iran; Passport A2463775 (Iran) (individual) [NPWMD] -to- QASEMI, Rostam (a.k.a. GHASEMI MOHAMMADALI, ROSTAM), Iran; citizen Iran; nationality Iran; Passport A2463775 (Iran) (individual) |[NPWMD] [IRGC]|


RAH SAHEL INSTITUTE, Tehran, Iran [NPWMD] -to- RAH SAHEL INSTITUTE, Tehran, Iran |[NPWMD] [IRGC]|


RAHAB INSTITUTE (f.k.a. RAHSAZ INSTITUTE), Ghorb-e Ghaem Building, Valiasr St., Azizi Blvd., Azadi Sq., Tehran, Iran; Eastern 14th St., Beihaghi Blvd., Arjantin Sq., Tehran, Iran [NPWMD] -to- RAHAB INSTITUTE (f.k.a. RAHSAZ INSTITUTE), Ghorb-e Ghaem Building, Valiasr St., Azizi Blvd., Azadi Sq., Tehran, Iran; Eastern 14th St., Beihaghi Blvd., Arjantin Sq., Tehran, Iran |[NPWMD] [IRGC]|


REZAIE, Morteza (a.k.a. REZAI, Morteza); DOB circa 1956; citizen Iran; nationality Iran (individual) [NPWMD] -to- REZAIE, Morteza (a.k.a. REZAI, Morteza); DOB circa 1956; citizen Iran; nationality Iran (individual) |[NPWMD] [IRGC]|


SAFAVI, Yahya Rahim (a.k.a. AL-SIFAWI, Yahya Rahim; a.k.a. RAHIM SAFAWI, Yahia; a.k.a. RAHIM-SAFAVI, Yahya; a.k.a. SAFAVI, Rahim; a.k.a. YAHYA RAHIM-SAFAVI, Seyyed; a.k.a. YAHYA SAFAVI, Sayed); DOB circa 1952; POB Esfahan, Iran (individual) [NPWMD] -to- SAFAVI, Yahya Rahim (a.k.a. AL-SIFAWI, Yahya Rahim; a.k.a. RAHIM SAFAWI, Yahia; a.k.a. RAHIM-SAFAVI, Yahya; a.k.a. SAFAVI, Rahim; a.k.a. YAHYA RAHIM-SAFAVI, Seyyed; a.k.a. YAHYA SAFAVI, Sayed); DOB circa 1952; POB Esfahan, Iran (individual) |[NPWMD] [IRGC]|


SAHEL CONSULTANT ENGINEERS, No. 57, Eftekhar St., Larestan St., Motahhari Ave, Tehran, Iran; P.O. Box 16765-34, Tehran, Iran [NPWMD] -to- SAHEL CONSULTANT ENGINEERS, No. 57, Eftekhar St., Larestan St., Motahhari Ave, Tehran, Iran; P.O. Box 16765-34, Tehran, Iran |[NPWMD] [IRGC]|


SALIMI, Hosein (a.k.a. SALAMI, Hoseyn; a.k.a. SALAMI, Hossein; a.k.a. SALAMI, Hussayn); citizen Iran; nationality Iran; Passport D08531177 (Iran) (individual) [NPWMD] -to- SALIMI, Hosein (a.k.a. SALAMI, Hoseyn; a.k.a. SALAMI, Hossein; a.k.a. SALAMI, Hussayn); citizen Iran; nationality Iran; Passport D08531177 (Iran) (individual) |[NPWMD] [IRGC]|


SEPANIR OIL AND GAS ENGINEERING COMPANY (a.k.a. SEPANIR; a.k.a. SEPANIR ESTABLISHMENT), No. 319 Shahid Bahonar Street, Tehran, Iran [NPWMD] -to- SEPANIR OIL AND GAS ENGINEERING COMPANY (a.k.a. SEPANIR; a.k.a. SEPANIR ESTABLISHMENT), No. 319 Shahid Bahonar Street, Tehran, Iran |[NPWMD] [IRGC]|


SEPASAD ENGINEERING COMPANY, No. 4 Corner of Shad St., Mollasadra Ave., Vanak Square, Tehran, Iran [NPWMD] -to- SEPASAD ENGINEERING COMPANY, No. 4 Corner of Shad St., Mollasadra Ave., Vanak Square, Tehran, Iran |[NPWMD] [IRGC]|


SHAHLAI, Abdul Reza (a.k.a. SHAHLAEE, Abdul-Reza; a.k.a. SHAHLAI, Abdol Reza; a.k.a. SHAHLA'I, Abdolreza; a.k.a. SHAHLAI, 'Abdorreza; a.k.a. SHALAI, 'Abd-al Reza; a.k.a. SHALA'I, Abdul Reza; a.k.a. "ABU-AL-KARKH', 'Yusuf"; a.k.a. "YASIR, Hajji"; a.k.a. "YUSEF, Hajj"; a.k.a. "YUSIF, Haji"; a.k.a. "YUSIF, Hajji"), Mehran Military Base, Ilam Province, Iran; Kermanshah, Iran; DOB circa 1957 (individual) [IRAQ3] -to- SHAHLAI, Abdul Reza (a.k.a. SHAHLAEE, Abdul-Reza; a.k.a. SHAHLAI, Abdol Reza; a.k.a. SHAHLA'I, Abdolreza; a.k.a. SHAHLAI, 'Abdorreza; a.k.a. SHALAI, 'Abd-al Reza; a.k.a. SHALA'I, Abdul Reza; a.k.a. "ABU-AL-KARKH', 'Yusuf"; a.k.a. "YASIR, Hajji"; a.k.a. "YUSEF, Hajj"; a.k.a. "YUSIF, Haji"; a.k.a. "YUSIF, Hajji"), |Kermanshah, Iran; Mehran Military Base, Ilam Province, Iran; DOB circa 1957| (individual) |[IRAQ3] [IRGC]|


SOLEIMANI, Qasem (a.k.a. SALIMANI, Qasem; a.k.a. SOLAIMANI, Qasem; a.k.a. SOLEMANI, Qasem; a.k.a. SOLEYMANI, Ghasem; a.k.a. SOLEYMANI, Qasem; a.k.a. SULAIMANI, Qasem; a.k.a. SULAYMAN, Qasmi; a.k.a. SULEMANI, Qasem); DOB 11 Mar 1957; POB Qom, Iran; citizen Iran; nationality Iran; Diplomatic Passport 008827 (Iran) issued 1999 (individual) [NPWMD] -to- SOLEIMANI, Qasem (a.k.a. SALIMANI, Qasem; a.k.a. SOLAIMANI, Qasem; a.k.a. SOLEMANI, Qasem; a.k.a. SOLEYMANI, Ghasem; a.k.a. SOLEYMANI, Qasem; a.k.a. SULAIMANI, Qasem; a.k.a. SULAYMAN, Qasmi; a.k.a. SULEMANI, Qasem); DOB 11 Mar 1957; POB Qom, Iran; citizen Iran; nationality Iran; Diplomatic Passport 008827 (Iran) issued 1999 (individual) |[NPWMD] [IRGC]|


ZAHEDI, Mohammed Reza (a.k.a. MAHDAVI, Reza; a.k.a. MAHDAWI, Hasan; a.k.a. ZAHDI, Mohammad Riza; a.k.a. ZAHEDI, Ali Reza), Beirut, Lebanon; DOB 1944; POB Esfahan, Iran; nationality Iran (individual) [SDGT] -to- ZAHEDI, Mohammed Reza (a.k.a. MAHDAVI, Reza; a.k.a. MAHDAWI, Hasan; a.k.a. ZAHDI, Mohammad Riza; a.k.a. ZAHEDI, Ali Reza),  Beirut, Lebanon; DOB 1944; POB Esfahan, Iran; nationality Iran (individual) |[SDGT] [IRGC]|


 



8/20/2010 5:57:49 PM
Topic: Barclays Settles Sanctions Violations

Admin
Posts 393

08/18/2010


Barclays Bank PLC Settles Allegations of Violations of Multiple Sanctions Programs.


Barclays Bank PLC has agreed to settle allegations of violations of the Sudanese Sanctions Regulations, 31 C.F.R. Part 538; the Iranian Transactions Regulations, 31 C.F.R. Part 560; the Burmese Sanctions Regulations, 31 C.F.R. Part 537; and the Cuban Assets Control Regulations, 31 C.F.R. Part 515, promulgated under either the International Emergency Economic Powers Act (“IEEPA&rdquo, 50 U.S.C. §§ 1701-06, or the Trading With the Enemy Act (“TWEA&rdquo, 50 U.S.C. App. §§ 1-44. Barclays’ settlement with the Office of Foreign Assets Control (“OFAC&rdquo  is part of a global settlement among Barclays, OFAC, the U.S. Department of Justice, and the New York County District Attorney’s Office. The bank agreed to settle with OFAC the alleged violations of OFAC regulations for $176,000,000, with the obligation deemed satisfied by a payment of $298,000,000 to the Department of Justice and the New York County District Attorney’s Office. The Board of Governors of the Federal Reserve System and the New York State Banking Department have taken regulatory action against the bank through the issuance of a consent Cease and Desist Order. The British Financial Services Authority, as the home country regulator of Barclays, will be assisting OFAC and the U.S. bank supervisors in assuring proactive remediation.


Barclays’ apparent violations arose out of practices designed to circumvent filters at U.S. banks installed to detect transactions in violation of OFAC regulations. This was done using cover payments to avoid referencing parties targeted by U.S. sanctions and omitting or removing information in payment messages in order to conceal the identities of U.S. sanctions targets – most notably Sudan – in electronic funds transfer instructions executed through the United States. In addition, Barclays sometimes processed payments involving sanctioned persons through a Barclays sundry account, making it appear as though Barclays was the remitting bank. Based on OFAC’s analysis of information provided by Barclays, from August 2002 through September 2006, Barclays routed at least 1,285 electronic funds transfers, with an aggregate value of approximately $112,695,000, through Barclays New York and third-party banks located in the United States, in apparent violation of IEEPA or TWEA and the OFAC regulations related to the sanctions programs cited above.


Barclays has terminated the practices that led to the alleged illegal activities, has cooperated fully with OFAC, and has put in place policies and procedures that are designed to minimize the risk of the recurrence of similar conduct in the future. Barclays voluntarily self-disclosed the apparent violations under the terms of OFAC’s Economic Sanctions Enforcement Guidelines (“the Guidelines&rdquo. The total base penalty amount under the Guidelines for all apparent violations was approximately $218,971,000. OFAC mitigated the total potential penalty based on Barclays’ substantial cooperation, its remediation, the fact that OFAC had not issued a penalty notice or Finding of Violation against Barclays in the five years preceding the transactions at issue, and Barclays’ willingness to enter into tolling agreements with OFAC. Mitigation was also extended because a number of the Sudan transactions involved the export of agricultural products. At the same time, aggravating circumstances – including the recklessness of the apparent violations, awareness of the conduct by relevant managers within the bank, and sophistication of the institution – partially offset the amount of mitigation.


For the next two years, Barclays will conduct annual reviews of its policies and procedures and their implementation, and an appropriate risk-based sampling of U.S. dollar payments to ensure that its OFAC compliance program is functioning effectively to detect, correct, and report OFAC-sanctioned transactions when they occur. The entire Settlement Agreement between OFAC and Barclays is posted under the Selected Settlement Agreements section of this website.



8/20/2010 5:53:29 PM
Topic: Barclays Bank Settles OFAC Sanctions Program Fines

Admin
Posts 393

08/18/2010


Barclays Bank PLC Settles Allegations of Violations of Multiple Sanctions Programs.


Barclays Bank PLC has agreed to settle allegations of violations of the Sudanese Sanctions Regulations, 31 C.F.R. Part 538; the Iranian Transactions Regulations, 31 C.F.R. Part 560; the Burmese Sanctions Regulations, 31 C.F.R. Part 537; and the Cuban Assets Control Regulations, 31 C.F.R. Part 515, promulgated under either the International Emergency Economic Powers Act (“IEEPA&rdquo, 50 U.S.C. §§ 1701-06, or the Trading With the Enemy Act (“TWEA&rdquo, 50 U.S.C. App. §§ 1-44. Barclays’ settlement with the Office of Foreign Assets Control (“OFAC&rdquo  is part of a global settlement among Barclays, OFAC, the U.S. Department of Justice, and the New York County District Attorney’s Office.


The bank agreed to settle with OFAC the alleged violations of OFAC regulations for $176,000,000, with the obligation deemed satisfied by a payment of $298,000,000 to the Department of Justice and the New York County District Attorney’s Office. The Board of Governors of the Federal Reserve System and the New York State Banking Department have taken regulatory action against the bank through the issuance of a consent Cease and Desist Order. The British Financial Services Authority, as the home country regulator of Barclays, will be assisting OFAC and the U.S. bank supervisors in assuring proactive remediation.


Barclays’ apparent violations arose out of practices designed to circumvent filters at U.S. banks installed to detect transactions in violation of OFAC regulations. This was done using cover payments to avoid referencing parties targeted by U.S. sanctions and omitting or removing information in payment messages in order to conceal the identities of U.S. sanctions targets – most notably Sudan – in electronic funds transfer instructions executed through the United States. In addition, Barclays sometimes processed payments involving sanctioned persons through a Barclays sundry account, making it appear as though Barclays was the remitting bank. Based on OFAC’s analysis of information provided by Barclays, from August 2002 through September 2006, Barclays routed at least 1,285 electronic funds transfers, with an aggregate value of approximately $112,695,000, through Barclays New York and third-party banks located in the United States, in apparent violation of IEEPA or TWEA and the OFAC regulations related to the sanctions programs cited above.


Barclays has terminated the practices that led to the alleged illegal activities, has cooperated fully with OFAC, and has put in place policies and procedures that are designed to minimize the risk of the recurrence of similar conduct in the future. Barclays voluntarily self-disclosed the apparent violations under the terms of OFAC’s Economic Sanctions Enforcement Guidelines (“the Guidelines&rdquo. The total base penalty amount under the Guidelines for all apparent violations was approximately $218,971,000. OFAC mitigated the total potential penalty based on Barclays’ substantial cooperation, its remediation, the fact that OFAC had not issued a penalty notice or Finding of Violation against Barclays in the five years preceding the transactions at issue, and Barclays’ willingness to enter into tolling agreements with OFAC. Mitigation was also extended because a number of the Sudan transactions involved the export of agricultural products. At the same time, aggravating circumstances – including the recklessness of the apparent violations, awareness of the conduct by relevant managers within the bank, and sophistication of the institution – partially offset the amount of mitigation.


edited by Admin on 8/20/2010

8/20/2010 5:49:38 PM
Topic: Enforcement Actions

Admin
Posts 393

 


ENTITIES – 31 CFR 501.805(d)(1)(i)

Banco Colpatria, S.A., ("Colpatria") on behalf of the former Banco Colpatria, S.A., Miami Agency, which discontinued its operations in 2007 ("Colpatria Miami"), has remitted $91,849 to settle allegations of prohibited transactions involving blocked property under OFAC’s Narcotics Trafficking Sanctions Regulations ("NTSR") occurring between November 22, 2004 and May 24, 2005, without admitting or denying liability. OFAC alleged that Colpatria Miami violated the NTSR by processing 26 dollar-denominated wire transfers on behalf of one Colpatria corporate client, after OFAC designated the corporate client’s beneficial owners as Special Designated Narcotics Traffickers ("SDNTs"). Although Colpatria Miami screened the names of the beneficial owners against the Specially Designated Nationals and Blocked Persons List ("SDN List") at the time that the account was opened, it did not screen the names as the SDN List was updated. After discovering that the corporate client’s beneficial owners had been designated as SDNTs, Colpatria Miami voluntarily self-disclosed this matter to OFAC. The base penalty amount for the alleged violations was $229,623. The settlement amount reflects OFAC’s consideration of the following General Factors: Colpatria Miami voluntarily self-reported this matter to OFAC; Colpatria Miami has no history of any OFAC violations; Colpatria Miami revised its software configuration to review automatically the names of authorized signatories and beneficial owners of accounts rather than just the names of the account holders when performing account opening and periodic name checks against OFAC’s SDN List; and Colpatria signed a tolling agreement with OFAC.


Banco Colpatria, S.A., on behalf of the former Banco Colpatria S.A., Miami Agency (closed) Settles Narcotics Trafficking Sanctions Regulations Allegations:



For more information regarding OFAC regulations, please go to:


 


http://www.treas.gov/offices/enforcement/ofac/lega



8/18/2010 5:19:43 PM
Topic: July MSB List 2010

Admin
Posts 393

 


This new July 2010 List, which is current as of July 20, 2010, contains data on 43,617 registered MSBs. This is an increase of 576 MSB registrations from the June 15, 2010 total of 43,041.


 


http://www.fincen.gov/financial_institutions/msb/pdf/msb_registration_list.pdf



8/13/2010 4:07:38 PM
Topic: Guidance on IRAN Import Prohibitions-No exceptions

Admin
Posts 393

Source: OFAC  Aug 12, 2010 

Guidance Regarding Import Prohibitions Imposed by the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010


On July 1, 2010, the President signed into law the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (the "Act"), which, among other things, prohibits the importation of Iranian-origin goods and services into the United States, effective 90 days after the Act’s date of enactment.


No exception to this prohibition may be made for the commercial importation of Iranian-origin goods described in section 560.534(a) of the Iranian Transactions Regulations (31 C.F.R. Part 560). The Office of Foreign Assets Control cannot authorize by general or specific license the commercial importation of such Iranian-origin goods (which include certain foodstuffs and carpets) on or after September 29, 2010. Consequently, the general license in section 560.534 of the ITR will be eliminated by September 29, 2010, and any such goods for commercial importation into the United States must be entered for consumption before that date.



8/13/2010 3:57:41 PM
Topic: OFAC Enforcements 8/13/2010

Admin
Posts 393

 


ENTITIES – 31 CFR 501.805(d)(1)(i)

Compass Bank Settles Sudanese Sanctions Regulations Allegations:

Compass Bank, Birmingham, AL, has remitted $607,500 to settle allegations of violations of the Sudanese Sanctions Regulations, 31 C.F.R. Part 538 occurring during September 2006. OFAC alleged that Compass Bank acted without an OFAC license or outside the scope of its license by initiating three funds transfers on behalf of one of its clients related to the petroleum or petrochemical industries in Sudan. Compass Bank did not voluntarily disclose this matter to OFAC and the alleged violation constituted a non-egregious case. The base penalty amount was $750,000. The settlement amount reflects OFAC’s consideration of the following General Factors: Compass Bank has not previously received a Penalty Notice or Finding of Violation from OFAC; fully cooperated with OFAC during its investigation of this matter; and has undertaken significant remedial actions to strengthen its OFAC compliance program and to manage potential sanctions risk, not just in the area of funds transfers but more broadly across its entire business line.


 


 


Custom Polymers, Inc. Settles Sudanese Sanctions Violation Allegation: Custom Polymers, Inc., Charlotte, NC ("CPI") has agreed to remit $57,800 to settle an allegation of violation of the Sudanese Sanctions Regulations occurring on or about August 17, 2007. OFAC alleged that CPI attempted to make a payment involving Sudan, on behalf of its affiliate, without an OFAC license. The payment, which amounted to $116,250, was allegedly for the purchase and export of bottle regrind from Sudan. OFAC determined that CPI did not voluntarily disclose this matter to OFAC and the alleged violation constituted a non-egregious case. The base penalty amount for the violation totaled $170,000. The settlement amount reflects OFAC’s consideration of the following General Factors: CPI had no history of sanctions violations; CPI entered into the underlying contract with its supplier without knowledge or reason to know the goods were from Sudan; CPI immediately ceased all business activities with its supplier in order to avoid future U.S. sanctions violations; and CPI implemented a sanctions compliance program.



8/13/2010 3:53:04 PM
Topic: 8/13/2010 SDN List Updated

Admin
Posts 393

08/13/2010


The following entities have been added to OFAC's SDN list:

BUSHEHR SHIPPING COMPANY LIMITED, 143/1 Tower Road, Sliema, Slm 1604, Malta; Business Registration Document # C 37422 (Malta) issued 30 Nov 2005 [NPWMD]

ISI MARITIME LIMITED, 147/1, St. Lucia Street, Valletta, Vlt 1185, Malta; Business Registration Document # C 28940 (Malta) issued 23 Nov 2001 [NPWMD]

MARBLE SHIPPING LIMITED, 143/1 Tower Road, Sliema, Slm 1604, Malta; Business Registration Document # C 41949 (Malta) issued 25 Jul 2007 [NPWMD]


8/13/2010 9:59:46 AM
Topic: Loan Operations Officer Needed-Eustis, Florida

Jessica Stephenson
Posts 1

Description: The Loan Operations Officer is responsible for the administration and management of all loan operations functions of the bank. This person will ensure all loan documentation is prepared accurately and delivered timely, loans are processed and closed accurately and timely. COMPLIANCE - ensure all loans in the loan portfolio are in compliance  with all applicable laws and regulations; that loans are audited and reviewed on a regular basis. REPORTING - all loan reports are compiled and accurate, and made ready for review by senior management. TEAM MANAGEMENT - provide guidance and support to staff, plan training as necessary; monitor construction loans; ensure G/L accounts are balanced timely and all billing is processed; assist with problem resolution as needed; develop departmental processes and procedures as needed.



Requirements: Minimum of 3 years supervisory experience; progressive commercial and residential loan processing experience in a banking environment; must be able to demonstrate all stages of loan processing; must have a thorough and communicable knowledge of lending laws and regulations; intermediate/advanced Excel spreadsheet skills; working knowledge of Fiserv, Laserpro software; excellent oral and written communication skills; high school diploma or equivalent, some college.



Only applicants with the requirements listed will be contacted. Please fax resumes to 352-483-9109.



First Green Bank


1301 South Bay Street


Eustis, FL 32726




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