International Law Advisory - OFAC Updates SDN List

Yesterday, the U.S. Treasury Department, Office of Foreign Assets Control (“OFAC”) made additions to the Specially Designated Nationals and Blocked Persons List (the “SDN List”), and accordingly froze the assets of the listed parties.  All of the additions to the SDN List, primarily Iraqi and Jordanian nationals, have been identified as IRAQ2 designations residing in the United Arab Emirates, Jordan, and Iraq.

On August 29, 2003, President George W. Bush issued Executive Order 13315, entitled “Blocking Property Of The Former Iraqi Regime, Its Senior Officials And Their Family Members, And Taking Certain Other Actions.”  Overall, the aforementioned Executive Order expands the scope of the national emergency declared in Executive Order 13303, thereby further ensuring the orderly reconstruction of Iraq.  IRAQ2 designations are made pursuant to Executive Order 13315.

The SDN List has been revised to include the following new information:

• ALFA COMPANY LIMITED FOR INTERNATIONAL TRADING AND MARKETING (a.k.a. ALFA INVESTMENT AND INTERNATIONAL TRADING COMPANY; a.k.a. ALFA TRADING COMPANY), P.O. Box 910606, Amman 11191, Jordan [IRAQ2]
• BURHAN, Dr. Sahir (a.k.a. AL-DEEN, Saher Burhan; a.k.a. BARHAN, Dr. Sahir; a.k.a. BERHAN, Dr. Sahir; a.k.a. BURHAN, Sahir), United Arab Emirates; Baghdad, Iraq; DOB 1967; nationality Iraqi (individual) [IRAQ2]
• HAMUDAT, General Maki Mustafa (a.k.a. AL-HAMADAT, General Maki; a.k.a. HAMUDAT, Maki; a.k.a. HMODAT, Mackie; a.k.a. MUSTAFA, Macki Hamoudat), Mosul, Iraq; DOB circa 1934; nationality Iraqi (individual) [IRAQ2]
• KARAM, Nabil Victor, c/o TRADING AND TRANSPORT SERVICES, Al-Razi Medical Complex, Jabal Al- Hussein, Amman, Jordan; c/o TRADING AND TRANSPORT SERVICES, P.O. Box 212953, Amman 11121, Jordan; c/o TRADING AND TRANSPORT SERVICES, P.O. Box 910606, Amman 11191, Jordan; c/o ALFA COMPANY LIMITED FOR INTERNATIONAL TRADING AND MARKETING, P.O. Box 212953, Amman 11121, Jordan; c/o ALFA COMPANY LIMITED FOR INTERNATIONAL TRADING AND MARKETING, P.O. Box 910606, Amman 11191, Jordan; DOB 1954; nationality Lebanese (individual) [IRAQ2]
• SHABAN, Adib (a.k.a. AL-ANI, Adib Shaban; a.k.a. SHABAN, Dr. Adib); DOB 1952; nationality Iraqi (individual) [IRAQ2]
• SLEWA, Roodi (a.k.a. SALIWA, Rudi; a.k.a. SLAIWAH, Rudi; a.k.a. SLAY WAH, Rudi Untaywan) nationality Iraqi (individual) [IRAQ2]
• TABRAH, Asil Sami Mohamad Madhi (a.k.a. TABRA, Asil); DOB 19 Jun 1964; nationality Iraqi (individual) [IRAQ2]
• TRADING AND TRANSPORT SERVICES COMPANY, LTD., Al-Razi Medical Complex, Jabal Al-Hussein, Amman, Jordan; P.O. Box 212953, Amman 11121, Jordan; P.O. Box 910606, Amman 11191, Jordan [IRAQ2]

Companies should update their OFAC compliance screening mechanisms to ensure that any existing business relationships or transactions, and any relationships or transactions in the future, are in compliance with the revised SDN List.

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