2002/08/29
By: John Black
In the August 23, 2002 Federal Register the State Department announced that it is imposing missile proliferation sanctions against:
Changgwang Sinyong Corporation (North Korea) and its sub-units and successors
The sanctions require that the State and Commerce departments deny all license applications for transfers to this party of items controlled for missile technology reasons or controlled by the Missile Technology Regime Annex. The sanctions also prohibit the US Government from entering into contracts that involve this entity and the same missile-related items.
The State Department also imposed similar sanctions to all missile-related activities of the North Korean Government. Specifically no export licenses will be approved for missile-related items to missile-related activities of the North Korean Government and no US Government contracts for the same.
Reportedly, these sanctions were imposed because Changgwang, Sinyong Corporation, the missile-marketing arm of the North Korean Government, transferred missile-related items to Yemen.
As a practical matter, the stated scope of the sanctions (i.e., license denial) will have very little (if any) impact on exporters and reexporters because it would be difficult to obtain a license for missile related items for any party in North Korea even if there were no sanctions.
The only real impact of the sanctions comes in an area that the sanctions do not explicitly seem to impact. The sanctions do not explicitly prohibit the export of items classified as EAR99 in the Commerce Control List as No License Required (NLR) to Changgwang Sinyong. Exporters and reexporters, however, should proceed cautiously with any transaction involving EAR99 items and Changgwang Sinyong. The fact that the State Department has imposed missile proliferation sanctions on Changgwang Sinyong means that you now know this entity is involved in missile-related activities, which may mean that you have a “reason to know” that any transaction with Changgwang Sinyong may involve missile-related activities. And you may not ship EAR99 items as No License Required to any missile-related activity in North Korea.
What should you do? Add Changgwang Sinyong to your export denial list with a code that identifies them as being subject to missile sanctions. As you use this list to screen transactions, if you ever get a match with Changgwang Sinyong, you should thoroughly investigate the transaction to see if you can find any evidence of missile-related activities before you proceed with the transaction.
The State Department published Federal Register notices on August 9 and 15, 2002, identifying the following entities as foreign terrorist organizations:
The Communist Party of the Philippines (CCP) also known as the New People’s Army (NPA); and
Jose Maria Sison
On August 27, 2002 OFAC announced on its web site that it is removing these parties from its list of Specially Designated Nationals and Blocked Persons on its website:
AARAN MONEY WIRE SERVICE INC., 1806 Riverside Ave., 2nd Floor, Minneapolis, Minnesota, U.S.A. [SDGT]
ADEN, Abdirisak, Skaftingebacken 8, Spanga 163 67, Sweden; DOB 01 Jun 68 (individual) [SDGT]
ALI, Abdi Abdulaziz, Drabantvagen 21, Spanga 177 50, Sweden; DOB 01 Jan 1955 (individual) [SDGT]
BARAKAAT ENTERPRISE, 1762 Huy Rd., Columbus, Ohio 43224-3550, U.S.A. [SDGT]
GLOBAL SERVICE INTERNATIONAL, 1929 5th St., Suite 204, Minneapolis, Minnesota, U.S.A. [SDGT]
JAMA, Garad (a.k.a. NOR, Garad K.; a.k.a. WASRSAME, Fartune Ahmed), 2100 Bloomington Ave., Minneapolis, Minnesota, U.S.A.; 1806 Riverside Ave., 2nd Floor, Minneapolis, Minnesota, U.S.A.; DOB 26 Jun 1974 (individual) [SDGT]
NOR, Garad K. (a.k.a. JAMA, Garad; a.k.a. WASRSAME, Fartune Ahmed), 2100 Bloomington Ave., Minneapolis, Minnesota U.S.A.; 1806 Riverside Ave., 2nd Floor, Minneapolis, Minnesota, U.S.A.; DOB 26 Jun 1974 (individual) [SDGT]
WASRSAME, Fartune Ahmed (a.k.a. JAMA, Garad; a.k.a. NOR, Garad K.), 2100 Bloomington Ave., Minneapolis, Minnesota U.S.A.; 1806 Riverside Ave., 2nd Floor, Minneapolis, Minnesota, U.S.A.; DOB 26 Jun 1974 (individual) [SDGT]
On August 29, 2002 OFAC added the following entities to its list of Specially Designated Nationals and Blocked Persons as SDGTs on its website:
AKIDA BANK PRIVATE LIMITED (f.k.a. AKIDA ISLAMIC BANK INTERNATIONAL LIMITED; f.k.a. IKSIR INTERNATIONAL BANK LIMITED), c/o Arthur D. Hanna & Company; 10 Deveaux Street, Nassau, Bahamas; P.O. Box N-4877, Nassau, Bahamas [SDGT]
AKIDA INVESTMENT CO. LTD. (a.k.a. AKIDA INVESTMENT COMPANY LIMITED; f.k.a. AKIDA BANK PRIVATE LIMITED), c/o Arthur D. Hanna & Company, 10 Deveaux Street, Nassau, Bahamas; P.O. Box N-4877, Nassau, Bahamas [SDGT]
BA TAQWA FOR COMMERCE AND REAL ESTATE COMPANY LIMITED, Vaduz, Liechtenstein; formerly c/o Asat Trust reg., Vaduz, Liechtenstein [SDGT]
GULF CENTER S.R.L., Corso Sempione 69, 20149 Milan, Italy; Italian Fiscal Code: 07341170152; V.A.T. Number: IT 07341170152 [SDGT]
MIGA-MALAYSIAN SWISS, GULF AND AFRICAN CHAMBER (f.k.a. GULF OFFICE ASSOC. PER LO SVILUPPO COMM. IND. E TURIS. FRA GLI STATI ARABI DEL GOLFO E LA SVIZZERA), Via Maggio 21, 6900 Lugano TI, Switzerland [SDGT]
NADA INTERNATIONAL ANSTALT, Vaduz, Liechtenstein; formerly c/o Asat Trust reg., Vaduz, Liechtenstein [SDGT]
NASCO BUSINESS RESIDENCE CENTER SAS DI NASREDDIN AHMED IDRIS EC, Corso Sempione 69, 20149 Milan, Italy; Italian Fiscal Code: 01406430155; V.A.T. Number: IT 01406430155 [SDGT]
NASCO NASREDDIN HOLDING A.S., Zemin Kat, 219 Demirhane Caddesi, Zeytinburnu, Istanbul, Turkey [SDGT]
NASCOSERVICE S.R.L., Corso Sempione 69, 20149 Milan, Italy; Italian Fiscal Code: 08557650150; V.A.T. Number: IT 08557650150 [SDGT]
NASCOTEX S.A. (a.k.a. INDUSTRIE GENERALE DE FILATURE ET TISSAGE; a.k.a. INDUSTRIE GENERALE DE TEXTILE), KM 7 Route de Rabat, BP 285, Tangiers, Morocco; KM 7 Route de Rabat, Tangiers, Morocco [SDGT]
NASREDDIN COMPANY NASCO SAS DI AHMED IDRIS NASREDDIN EC, Corso Sempione 69, 20149 Milan, Italy; Italian Fiscal Code: 03464040157; V.A.T. Number: IT 03464040157 [SDGT]
NASREDDIN GROUP INTERNATIONAL HOLDING LIMITED (a.k.a. NASREDDIN GROUP INTERNATIONAL HOLDINGS LIMITED), c/o Arthur D. Hanna & Company; 10 Deveaux Street, Nassau, Bahamas; P.O. Box N-4877, Nassau, Bahamas [SDGT]
NASREDDIN INTERNATIONAL GROUP LIMITED HOLDING (a.k.a. NASREDDIN INTERNATIONAL GROUP LTD. HOLDING), c/o Rechta Treuhand-Anstalt, Vaduz, Liechtenstein; Corso Sempione 69, 20149, Milan, Italy [SDGT]
NASREDDIN FOUNDATION (a.k.a. NASREDDIN STIFTUNG), c/o Rechta Treuhand-Anstalt, Vaduz, Liechtenstein [SDGT]
On August 29, 2002 OFAC added the following inidividuals to its list of Specially Designated Nationals and Blocked Persons as SDGTs on its website:
BEN SOLTANE, Adel, Via Latisana n. 6, Milan, Italy; DOB 14 Jul 1970; POB Tunis, Tunisia; Italian Fiscal Code: BNSDLA70L14Z352B (individual) [SDGT]
BENATTIA, Nabil; DOB 11 May 1966; POB Tunis, Tunisia (individual) [SDGT]
CHEKKOURI, Yassine; DOB 6 Oct 1966; POB Safi, Morocco (individual) [SDGT]
JELASSI, Riadh; DOB 15 Dec 1970; POB Tunisia (individual) [SDGT]
KAMMOUN, Mehdi, Via Masina n.7, Milan, Italy; DOB 3 Apr 1968; POB Tunis, Tunisia; Italian Fiscal Code:
KMMMHD68D03Z352N (individual) [SDGT]
KISHK, Samir; DOB 14 May 1955; POB Gharbia, Egypt (individual) [SDGT]
MAAROUFI, Tarek Ben Habib; DOB 23 Nov 1965; POB Ghardimaou, Tunisia (individual) [SDGT]
REMADNA, Abdelhalim; DOB 2 Apr 1966; POB Bistra, Algeria (individual) [SDGT]
THAER, Mansour; DOB 21 Mar 1974; POB Baghdad, Iraq (individual) [SDGT]
TLILI, Lazhar Ben Mohammed, Via Carlo Porta n.97, Legnano, Italy; DOB 26 Mar 1969; POB Tunis, Tunisia; Italian Fiscal Code: TLLLHR69C26Z352G (individual) [SDGT]
WADDANI, Habib, Via unica Borighero n.1, San Donato M.se (MI), Italy; DOB 10 Jun 1970; POB Tunis, Tunisia; Italian Fiscal Code: WDDHBB70H10Z352O (individual) [SDGT]
On August 13, 2002 OFAC removed these entieis from its SDN list by making the following announcement:
“PLATINUM COMMERCIAL BANK and Pakistani authorities have now provided sufficient information to have the name of the bank removed from OFAC’s SDN list. Its financial assets are no longer blocked pending investigation pursuant to the Libyan Sanctions Regulations, 31 C.F.R. Part 550, and Section 203 of the International Emergency Economic Powers Act, as amended, 50 U.S.C. 1702. The following entry has been deleted:
PLATINUM COMMERCIAL BANK LTD., Head Office: 76-B Block E-1, Main Blvd., Gulberg III, Lahore 54000, Punjab, Pakistan; Main Office: SRI, Business & Finance Center, Plot No. 7/3 I.I. Chundrigar Rd., Karachi 74200, Sindh, Pakistan; 76 Abdali Rd., Multan, Punjab, Pakistan; all other offices located in Pakistan [BPI-LIBYA]”
On August 12, 2002 OFAC added the following inidividuals to its list of Specially Designated Nationals and Blocked Persons as SDGTs on its website:
NEW PEOPLE’S ARMY / COMMUNIST PARTY OF THE PHILIPPINES (a.k.a. COMMUNIST PARTY OF THE PHILIPPINES; a.k.a. CPP; a.k.a. NEW PEOPLE’S ARMY; a.k.a. NPA; a.k.a. NPA/CPP) [FTO] [SDGT]
SISON, Jose Maria (a.k.a. LIWINAG, Armando), The Netherlands; DOB 8 Feb 1938; POB Llocos Sur, Northern Luzon, Philippines (individual) [SDGT]
On August 12, 2002 OFAC removed the following entry has been removed from its SDN list on its website:
DONNEYS GONZALEZ, Federico, c/o DISTRIBUIDORA DE DROGAS CONDOR LTDA., Bogota, Colombia (individual) [SDNT]