International Law Advisory - SDN List - August

OFAC Blocks the Assets of Twenty-five Individuals and Entities, Many that Are Located in Europe

The US Department of Treasury, Office of Foreign Assets Control ("OFAC") blocked the assets of twenty-five individuals and entities linked to the Al-Qaida terrorist network on August 29, 2002.  Including the twenty-five entities added in yesterday’s announcement, there are presently 234 persons on the OFAC list of Specially Designated Nationals ("SDN List") for financing terrorism.  The list of the twenty-five entities is attached for your information.

This latest addition to the SDN List is unique in that it is the result of a multilateral effort by the United States, Italy, Luxembourg, and the Bahamas to identify financial sources for the Al-Qaida and other terrorist organizations.  Italy has simultaneously blocked the assets of the twenty-five entities as well.

Of significant interest, the twenty-five individuals and entities differ from previous additions to the SDN list in that these individuals and entities are primarily from countries with which companies routinely transact business.  Commonly the blocked entities have been from an embargoed country or from a country often considered a rogue nation (e.g., Iran, Iraq, and Afghanistan).  As you will see on the list below, these latest blocked entities are from Switzerland, Italy, the Bahamas, and Turkey, among others.  Therefore, in light of this latest announcement, companies should be diligent before entering into any transaction to ensure that a blocked entity is not involved.

We will continue to keep you apprised of sanctions and export control developments.  If you have any questions, please feel free to contact Ed Krauland at 202.429.8083.