International Law Advisory - FAC Publishes Federal Register Notices Designating Bank Sepah and Syrian Entities

On February 21, 2007, the US Treasury Department, Office of Foreign Assets Control (“OFAC”) published two notices in the Federal Register announcing the designation under the Specially-Designated Nationals (“SDN”) List of Iran’s Bank Sepah and related entities, and a number of Syrian entities.1 

These entities in fact were designated in early January (see our January 12, 2007 advisory discussing the Bank Sepah designations), but their designations were not published in the Federal Register until February 21.  The full list of this week’s additions reads as follows:

• BANK SEPAH, IMAM KHOMEINI SQUARE, P.O. Box 11364-9569, Tehran, Iran; all offices worldwide [NPWMD]
• BANK SEPAH INTERNATIONAL PLC, 5/7 Eastcheap, London EC3M 1JT, United Kingdom [NPWMD]
• DERAKHSHANDEH, AHMAD, c/o BANK SEPAH, No. 33 Hormozan Building, Pirozan St., Sharak Ghods, Tehran, Iran; DOB 11 Aug 1956; POB Iran [NPWMD]
• HIGHER INSTITUTE OF APPLIED SCIENCE AND TECHNOLOGY (a.k.a. HIAST; a.k.a INSTITUT DES SCIENCES APPLIQUEES ET DE TECHNOLOGIE; a.k.a. INSTITUT SUPERIEUR DES SCIENCES APPLIQUEES ET DE TECHNOLOGIE; a.k.a. ISAT; a.k.a ISSAT), P.O. Box 31983, Barzeh, Damascus (Syria) [NPWMD]
• ELECTRONICS INSTITUTE, P.O. Box 4470, Damascus (Syria) [NPWMD]
• NATIONAL STANDARDS AND CALIBRATION LABORATORY (a.k.a. NSCL; a.k.a NATIONAL CALIBRATION CENTRE), P.O. Box 4470, Damascus (Syria) [NPWMD]

As a result of these designations, which were made pursuant to Presidential Executive Order No. 13382, the property and interests in property of the designated entities are blocked as of the dates of the designations in early January. US persons must, therefore, ensure that they do not engage in business transactions with these entities. As highlighted in our advisory of January 12, 2007, of particular note is the addition of Iranian state-owned bank, Bank Sepah, given that the designations include a subsidiary of Bank Sepah located in London. 

The designations summarized herein are supplemental to the wide-ranging economic sanctions restrictions applicable to dealings by US persons with Iranian entities under the Iranian Transaction Regulations (31 C.F.R. Part 560), and the Export Administration Regulations (“EAR”) (15 C.F.R. § 746.7), and the extensive EAR export and reexport controls applicable to Syria (15 C.F.R. § 736 Supp. 1 (General Order No. 2)). Although the Syrian export controls do not contain general restrictions on services, the provision by US persons of services to the Syrian entities designated on the SDN List would be restricted.

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 in Washington, DC, or David Lorello at +44 20 7367 8007 in London.

1. See, 72 Fed. Reg. 7919 and 72 Fed. Reg. 7919-7920.