OTHER THINGS YOU MAY HAVE MISSED – MARCH 26

26th March 2019

KAZAKH BANK CLAIMS NEW YORK DEVELOPER LAUNDERED MONEY IN TRUMP PROPERTY

KYC 360 on 26th March reported that Kazakhstan’s BTA Bank JSC has filed a lawsuit accusing a New York real estate developer of helping to launder tens of millions of dollars through a Trump-branded property and other US businesses.  It alleges that wealthy Kazakh businessman Ilyas Khrapunov worked with long-time Trump ally Felix Sater in the mid-2000s to launder a portion of the $4 billion purportedly stolen from the bank a decade ago by its former chairman and Khrapunov’s father-in-law, Mukhtar Ablyazov, using 3 units in the Trump SoHo project, which Sater and his firm Bayrock LLC were helping to develop

https://www.riskscreen.com/kyc360/news/kazakh-bank-claims-ny-developer-laundered-money-in-trump-property/

NEW US SANCTIONS PUT SPOTLIGHT ON IRANIAN RESEARCH INSTITUTE

Science on 25th March published an article concerned with the sanctions imposed this month on 31 entities and individuals linked to a military institute — known as the Organization for Defense Innovation and Research, or SPND — that US officials allege is maintaining nuclear weapons expertise under the guise of civilian R&D.  It describes them as a shot across the bow of all scientists in Iran contemplating working with SPND.  The institute was founded in 2011 by Mohsen Fakhrizadeh-Mahabadi, a physicist at Imam Hussein University in Tehran who Western intelligence agencies say orchestrated Iran’s nuclear bomb effort.  Iran refused IAEA access to Fakhrizadeh-Mahabadi when the agency was reviewing the “possible military dimensions” of Iran’s nuclear programme.  It says that a US official stressed that SPND is “completely separate from Iran’s civil nuclear programme,” which the US is not targeting with sanctions.

https://www.sciencemag.org/news/2019/03/new-us-sanctions-put-spotlight-iranian-research-institute

DOGON MILITIA HEAD DENIES HIS GROUP WAS BEHIND MALI MASSACRE OF 154

The Japan Times on 26th March reported that the head of an ethnic Dogon militia blamed for a massacre in central Mali denied that his fighters had been involved in the gruesome attack that left 154 dead in an ethnic Peuhl village.  Human Rights Watch has said that Toloba’s ethnic militia, known as Dan Na Ambassagou, has been implicated in scores of deadly attacks over the past year, as it accused ethnic Peuhl of collaborating with Islamic extremists increasingly operating in central Mali.  The Peuhl and Dogon ethnic groups had long co-existed peacefully but that has been unravelled over the last several years, and the conflict has been fuelled by a proliferation in arms and an Islamic insurgency moving ever further south from its strongholds in Mali’s north.

https://www.japantimes.co.jp/news/2019/03/26/world/crime-legal-world/dogon-militia-head-denies-group-behind-mali-massacre-154/#.XJm_M3d2t9A

SHUNNED BY WORLD, US SANCTION-HIT NATIONS’ CHEAP OIL FINDS HAVEN IN CHINA

Business Standard on 26th March carried an article saying that China bought 2.03 million metric tons, or 531,000 barrels a day, of crude from Venezuela last month, 17% more than January and the highest since December 2017.  China is also said to have been allotted 360,000 barrels daily under the exemption to Iranian US sanctions, though that excludes the share of oil owed to Chinese companies that hold stakes in Iranian projects.  It is said that China’s purchases are also probably spurred by a shortage of so-called heavy oil, which is more dense and sulfurous than lighter crude.

https://www.business-standard.com/article/markets/shunned-by-world-us-sanction-hit-nations-cheap-oil-finds-haven-in-china-119032600150_1.html

THE POSITION OF UK LIMITED COMPANIES IN AUSTRIA AFTER BREXIT

On 25th March, Bitterl König published a briefing saying that the last couple of years have seen a sharp increase in the numbers of companies registered in the UK but having their administrative headquarters in Austria – i.e. the popular private limited company (Ltd.).  These companies are recognised in Austria as UK companies according to the ECJ’s case law on the freedom of establishment.  In the absence of a Brexit deal, however, EU law will cease to apply to the UK once it has left the EU, and the risk is that limited liability company established under UK law but having its administrative seat in Austria would thus not be recognised according to Austrian law.

https://www.lexology.com/library/document.ashx?g=89b983dc-d5cd-4f6a-9997-8d2e8c13ac0a

TAKE MY MONEY, SAVE JET AIRWAYS, VIJAY MALLYA TWEETS

The Times of India on 26th March reported that liquor tycoon Mallya has again repeated his offer again and urged PSU (public sector) banks to take his money and let his airline survive.  Mallya is currently facing extradition to India from the UK, and is facing fraud and money laundering charges in India.

https://timesofindia.indiatimes.com/business/india-business/take-my-money-it-will-help-to-save-jet-airways-vijay-mallya-tweets-again/articleshow/68573202.cms

KENYA: TREASURY SETS UP AML UNIT

The Kenyans website on 26th March reported that a high-powered task force had been established to investigate the extent of money laundering in a bid to close loopholes used by criminals and cartels to clean illicit cash.  It will mainly focus on casinos, land and luxury vehicle transactions.  The task force comprises 30 state agencies including the judiciary, banks, saccos, real estate and gaming regulators.  It is expected to craft a national strategy on combating money laundering and terrorism financing by March 31st 2020.

https://www.kenyans.co.ke/news/38193-treasury-sets-anti-money-laundering-unit

IRELAND: MAN JAILED FOR LAUNDERING KINAHAN MONEY LOSES APPEAL

The Irish Times on 25th March reported that Paul Carew, given 8 years for laundering €660,000 linked to the Kinahan crime gang has lost an appeal against the severity of his sentence.

https://www.irishtimes.com/news/crime-and-law/courts/man-jailed-for-laundering-kinahan-money-loses-appeal-1.3837811

UPPING THE ANTE ON HUMAN RIGHTS DUE DILIGENCE

EurActiv on 25th March carried an article saying that the EU has a patchwork of laws promoting transparency and supply chain due diligence in some sectors, and is under increasing pressure to table new legislation to protect human rights.  A ‘Gearing up EU action in Responsible Business Conduct’ event, including the presentation of a shadow EU action plan for Responsible Business Conduct by MEPs, examines how such legislation should be shaped, what tools are needed by civil society, and how company sentiment towards such initiatives has evolved.

https://www.euractiv.com/section/economy-jobs/special_report/upping-the-ante-on-human-rights-due-diligence/

ENGLISH LAW AND IMPLIED TERMS – WHEN DOES THE COURT STEP IN AND IMPLY TERMS INTO A CONTRACT?

Forwarder Law on 25th March carried an article about implied terms – terms that have not been expressly agreed by the parties, the latter being stated in the contract.  It says that implied terms are not as straight forward as express terms, and require the courts to insert a term into a contract where the contract is incomplete and/or it is required for the contract to operate effectively.  They exist as a form of redress filling in the contractual gaps and principally seeking to preserve the legitimate expectations of the contracting parties.  The article looks at the common law provisions and how they are applied.

http://forwarderlaw.com/2019/03/25/english-law-and-implied-terms/

CROSS-BORDER CANNABIS INVESTMENT: MANAGING MONEY LAUNDERING RISK

On 25th March, White & Case published an article saying that Canada legalised recreational cannabis in October 2018 and it may be that other countries follow suit.  UK and US investors, and those who facilitate investments in legal recreational cannabis businesses overseas, need to be aware of money laundering risks that arise and what they can do to protect themselves.  It points out that, in the UK, cannabis is a controlled drug and it remains unlawful to possess, produce, grow and sell cannabis for recreational purposes.  While it may be legal in Canada, funds generated due to investment in the recreational cannabis sector may be classified as proceeds of crime in the UK.  In the US, funds derived strictly from Canada’s legal cannabis sector may not necessarily represent proceeds of crime, but there are sufficient risks for a US investor to be wary – and it says the situation in the US is far from straightforward.  The article suggests that, if UK investors, or others, are concerned that they may commit a substantive money laundering offence relating to investing in overseas cannabis production or distribution, they can make a SAR seeking consent to proceed from the NCA.  If consent is granted, then the investor will have a defence to a substantive money laundering offence in relation to the relevant transaction.

https://www.jdsupra.com/legalnews/cross-border-cannabis-investment-41915/

LIABILITY IN UNINCORPORATED ASSOCIATIONS

Irish law firm Matheson published an article on 25th March concerned with unincorporated associations – a group that does not have separate legal personality from its members. Unlike the case of a company, there is no separate body with limited liability.  The members of an unincorporated association have duties and liabilities to each other that stem from the rules of the association.  Sports clubs, local organisations, charitable fundraising groups or community groups very often comprise unincorporated associations.  The liability of members for any wrongdoing by other members of the group varies according to the wrongdoing that has taken place. Liability in unincorporated associations under Irish contract and tort law is summarised in the article.

https://www.matheson.com/news-and-insights/article/liability-in-unincorporated-associations

 CHINA CRACKS DOWN ON ‘HIMALAYAN VIAGRA’ USED TO BRIBE OFFICIALS

OCCRP on 25th March reported that Chinese anti-corruption authorities in the north-west Qinghai province have launched a 3-month campaign to crack down on “Himalayan Viagra,” a fungus that is more valuable than gold and is used to bribe officials.  The fungus, a genus called Ophiocordyceps sinensis, or cordyceps, lives on certain caterpillars in the mountainous regions of China and Tibet and has been used by traditional healers since ancient times.  It is thought to cure dozens of ailments, but it is mostly used to treat kidney disorders and male sexual problems.

https://www.occrp.org/en/27-ccwatch/cc-watch-briefs/9443-china-cracks-down-on-himalayan-viagra-used-to-bribe-officials

PROTECTION FROM PRYING EYES: TRUSTS IN THE CAYMAN ISLANDS

On 13th March, Carey Olsen published an article which says that the need for protection from the courts from disclosure was recently dealt with by the Grand Court of the Cayman Islands.  In that case, the Court was required to act as a judicial watchdog, with one eye on the private needs of locally established trusts and the other eye on the public requirements of open justice.  In this case, the Judge was satisfied that there was no public interest in open justice, which outweighed the countervailing interests of protecting the welfare of minor beneficiaries, protecting the private lives of adult beneficiaries, and generally protecting the Trustee’s ability to ‘peaceably hold and administer the trust assets’.

https://www.careyolsen.com/articles/protection-prying-eyes-trusts-cayman-islands

US CUSTOMS: FIGHTING THE OPIOID SCOURGE

An article in US Customs and Border Protection’s Frontline digital magazine says that CBP has a large role in battling the opioid emergency, because it is at the front lines, at the border.  It examines how CBP is attempting to combat the scourge, saying that CBP officials have created a broad strategy to combat opioids with 4 primary goals: enhance collaboration and information-sharing; produce actionable intelligence; target the opioid supply chain; and protect CBP personnel from exposure to opioids.  The article looks at each of these elements.

https://www.cbp.gov/frontline/fighting-opioid-scourge

UK IMMIGRATION CHANGES MARCH 2019

On 25th March, Osborne Clarke published an article saying that UKVI announced the latest changes on 7th March.  It says that the most significant changes relate to Tier 1, Tier 2 and the EU Settlement Scheme. In light of Brexit, there will be more significant changes to Tier 2 in the future.  Should the UK enter into a withdrawal agreement as it currently stands, this would be at the end of December 2020, when the transitional period is due to end (subject to any extension), or shortly thereafter.  The article details the changes involved.

https://www.osborneclarke.com/insights/uk-immigration-changes-march-2019/

THE CAUSES AND CONSEQUENCES OF US EXTRA-TERRITORIAL COUNTER-PROLIFERATION ENFORCEMENT

An article in the Contemporary Security Policy journal published on 25th March poses the question: how can a multilateral, norms-based international regime like UN SCR 540 contend with extraterritorial enforcement based on national interests?   The article argues that increased US extraterritorial counter-proliferation policies are a consequence of the inconsistent implementation of UN SCR 1540, adaptive and resilient proliferation networks, and a history of expanding legal interpretations of jurisdiction.  It finds that while US extra-territorial enforcement can effectively disrupt networks hiding in overseas jurisdictions, doing so creates disincentives for states to implement UN SCR 1540 obligations and undermines broader non-proliferation objectives.

https://www.tandfonline.com/doi/abs/10.1080/13523260.2019.1595882?journalCode=fcsp20

EUROPEAN STATES ALIGN THEMSELVES WITH EU SYRIA SANCTIONS

A news release from the EU on 26th March reported that North Macedonia, Montenegro, Serbia, Albania, Iceland, Liechtenstein, Norway, Moldova and Georgia have confirmed their alignment with EU sanctions on Syria.

https://www.consilium.europa.eu/en/press/press-releases/2019/03/26/declaration-by-the-high-representative-on-behalf-of-the-eu-on-the-alignment-of-certain-third-countries-concerning-restrictive-measures-against-syria/

HUMAN RIGHTS WATCH URGES UAE TO ENSURE FAIR TRIAL FOR 8 LEBANESE OVER HEZBOLLAH LINKS

Reuters on 25th March reported that the NGO had urged the UAE to ensure a fair trial for 8 Lebanese nationals accused of setting up a “terrorist cell” with links to Hezbollah in Lebanon.  They are all Shi’ite Muslims and have lived and worked in the UAE for more than 15 years, were arrested in late 2017 and early 2018.

https://uk.reuters.com/article/uk-emirates-security/human-rights-watch-urges-uae-to-ensure-fair-trial-for-eight-over-hezbollah-links-idUKKCN1R61SR

FORMER RUSSIAN GOVERNMENT MINISTER IS DETAINED IN EMBEZZLEMENT CASE

Meduza in Latvia reported on 26th March that the Russian Federal Investigative Committee has launched a criminal case against Mikhail Abyzov, Russia’s former Open Government Affairs minister, on suspicion of embezzling $62.2 million.

https://meduza.io/en/news/2019/03/26/former-russian-government-minister-is-detained-in-embezzlement-case

BILLIONAIRE HUMPHREY KARIUKI CHALLENGES DUAL CITIZENSHIP LAW IN KENYA

On 26th March, the Daily Nation reported that Business tycoon Humphrey Kariuki Ndegwa, the owner of Africa Spirits Limited who is facing a tax evasion investigation is also challenging the Kenyan law which means he faces a prison sentence for not declaring his dual nationality.  He is seeking the suspension of the section of the law that specifies a punishment for failure to disclose dual citizenship.  The Immigration Act prescribes a fine and 3 years’ imprisonment, or both, if one fails to disclose this status within 3 months of acquiring it.  Africa Spirits was closed down on February 8th after illegal ethanol and fake Kenya Revenue Authority stamps were found during an inspection.

https://www.nation.co.ke/news/Tycoon-tax-probe-fights-dual-citizenship-law/1056-5043072-esensj/index.html

DELOITTE BEING SUED OVER AUDIT OF BOOKS FOLLOWING MADOFF SCAM

The Irish Times on 26th March reported that the liquidators of 2 BVI firms that were found to be insolvent after jailed fraudster Bernie Madoff’s Ponzi scheme was discovered are suing accountants in Ireland who audited their books for 2 years.  In High Court proceedings, it is claimed Deloitte failed to conduct the audits in accordance with proper standards.

https://www.irishtimes.com/business/financial-services/deloitte-being-sued-over-audit-of-books-following-madoff-scam-1.3839459

MINER ENRC LAUNCHES $93 MILLION CLAIM AGAINST SFO

Reuters reported on 26th March that Eurasian Natural Resources Corporation (ENRC), a mining company being investigated by the SFO, has filed a £70 million legal claim against the investigator and prosecutor for alleged wrongful conduct.  It was delisted from the London Stock Exchange in 2013 after the SFO launched an investigation into allegations of fraud, bribery and corruption.

https://uk.reuters.com/article/uk-britain-enrc-sfo/miner-enrc-launches-93-million-claim-against-uk-fraud-office-idUKKCN1R72E7?rpc=401&

SOLICITOR LED ‘PONZI’ RUSE TO SUCK INVESTORS INTO DOOMED SCHEME, TRIBUNAL HEARS

On 26th March, the Law Society Gazette reported that a solicitor used his status to give the veneer of respectability to a Ponzi-type scheme that would ultimately rob investors of their life savings, the Solicitors Disciplinary Tribunal has heard.  Charles Valentine Fraser-Macnamara, in his capacity as sole director of Ecohouse Developments, (EDL), is alleged to have allowed misrepresentations to be made to potential investors in property schemes that would were doomed to failure.

https://www.lawgazette.co.uk/news/solicitor-led-ponzi-ruse-to-suck-investors-into-doomed-scheme-tribunal-hears/5069762.article

WEALTHY ARMENIANS JOIN DUBAI LAND RUSH

On 22nd March, OCCRP reported that Armenian government officials and businesspeople have flocked to Dubai in recent years, following rich people from around the world who have bought property.  Some, it says, have purchased expensive properties that appear to be at odds with their positions and known or likely salaries.  The article details some examples.

https://www.occrp.org/en/goldensands/wealthy-armenians-join-the-dubai-land-rush

HOME OFFICE TENDERING FOR A PARTNER TO CONDUCT AN AUDIT OF CORPORATE COMPLIANCE WITH THE REPORTING REQUIREMENTS SET OUT IN MODERN SLAVERY ACT

An article from Out-Law on 26th March said that the Home Office is tendering for a partner to conduct an audit of corporate compliance with the reporting requirements set out in section 54 of the UK’s Modern Slavery Act 2015.

https://www.out-law.com/en/articles/2019/March/uk-home-office-tendering-for-modern-slavery-act-compliance-role/

MALTA: CUSTOMS SEIZE 2 MORE CONTAINERS WITH €5.8 MILLION WORTH OF COCAINE

On 26th March, the Times of Malta reported that, just a week after a €32.4 million cocaine haul, Customs officers have found 51.6 kg of cocaine hidden in reefer containers at Malta Freeport.  During routine screening of containers transiting Malta, 7 containers with a high-risk route were selected for scanning by the Container Monitoring Unit.  Both containers found to contain cocaine were loaded with fruit and had come from South America en route to Albania.

https://www.timesofmalta.com/articles/view/20190326/local/customs-seize-two-more-containers-with-58m-worth-of-cocaine.705644

ALL KNOWN FCPA-RELATED ONGOING PROSECUTIONS, FUGITIVES, SENTENCING, AND PENDING APPEALS

On 26th March, a post on the FCPA Blog summarises the “FCPA Docket” for individuals, which includes all known FCPA-related ongoing prosecutions, fugitives, sentencing, and pending appeals, as of March 25th.

http://www.fcpablog.com/blog/2019/3/26/the-fcpa-docket-march-2019.html

188BET CLOSES UK AND IRELAND ONLINE GAMBLING OPERATIONS

On 26th March, Calvin Ayre reported that 188BET has “abruptly” announced the cessation of its activities in the UK, Ireland, Gibraltar and the Channel Islands.  Customers (of the mainly Asian-facing operator) were assured that 188Bet’s UK parent company was in no financial difficulty and that they would have until August 30th to withdraw any remaining funds.  It is said that its pursuit of a UK licence was widely viewed as a way for it to access sponsorship opportunities in UK football, which is wildly popular among Asian sports bettors, and dropping its UK-facing operations mean it will no longer be able to sponsor UK football.

https://calvinayre.com/2019/03/26/business/188bet-halts-uk-ireland-online-gambling-ops/

STOCK EXCHANGE OF HONG KONG SANCTIONS GUIDANCE LETTER

On 26th March, Hogan Lovells published an article about a guidance letter from the Stock Exchange of Hong Kong (HKEx) that provides additional clarity on the types of activities by listing applicants in jurisdictions, or with persons or entities, which are subject to economic or trade sanctions that may be a concern to the HKEx as it evaluates a listing applicant’s suitability for listing.  The Guidance Letter expands the jurisdictions whose sanctions regulations a listing applicant must consider beyond the original 4 jurisdictions that were covered in a previous guidance letter in 2013.  The 2013 guidance referred to sanctions imposed by the US, EU, UN and Australia. Now the applicant must consider laws and regulations of any jurisdiction that is relevant to the listing applicant and has sanctions related laws or regulations – presumably meaning that the applicant has to consider whether any jurisdiction with which it has a relevant nexus, has sanctions laws and regulations, and whether the listing applicant has complied with them. This may in practice require a bit of extra due diligence. It also introduces a new concept of a “Sanctions Trader” as an entity that will be subject to the guidance, and it states that a Sanctions Trader may not be suitable for listing.

https://www.jdsupra.com/legalnews/hkex-sanctions-guidance-letter-march-71952/

LEGAL EXPERT CRITICISES LAW BODY’S WARNING TO SOLICITORS

On 26th March, an article from the London School of Economics reports that Dr Blackwell, Assistant Professor of Law in LSE’s Department of Law has criticised the warning issued by the Solicitors Regulation Authority.  The warning notice issued by the SRA suggested that solicitors who facilitate tax avoidance are necessarily breaching the SRA Code of Conduct.  However, Dr Blackwell has said that the concept and facilitation of tax avoidance in and of itself does not necessarily entail such breaches or negligence.  He also says that the SRA has not altered their Code of Conduct, and the conclusions of the warning notice are inconsistent with established case law regarding the Code of Conduct; and that therefore it has arguably breached its own legal obligation to uphold the rule of law, by limiting the availability of legal advice to citizens.

http://www.lse.ac.uk/News/Latest-news-from-LSE/2019/03-Mar-19/Warning-solicitors-against-aiding-tax-avoidance-risks-undermining-the-rule-of-law

KENYAN DPP TO GO TO JERSEY OVER FRAUD AND MONEY LAUNDERING CASE

On 26th March, Capital News in Kenya reported that the DPP is set to make a trip to Jersey over the fraud and money laundering case against ex-Nambale MP, Chris Okemo, and former Kenya Power and Lighting Company CEO, Samuel Gichuru.  They are accused of abusing their offices by using proxy companies to squander public funds running into hundreds of millions, according to documents that were sent to the Kenyan Government by the bailiff and Chief Justice of Jersey 9 years ago.  Among other things, he will discuss how to circumvent legal hurdles facing their intended extradition.  The Supreme Court is set to hear and determine whether they should be extradited after the Court of Appeal quashed an earlier ruling granting the government permission.  The assets were recovered by the Royal Court of Jersey after Windward Trading Limited, which was at the centre of the scandal, pleaded guilty to 4 counts of money laundering.

https://www.capitalfm.co.ke/news/2019/03/dpp-headed-to-jersey-in-pursuit-of-justice-in-okemo-gichuru

EUROPEAN PARLIAMENT REPORT ACCUSES 7 COUNTRIES, INCLUDING CYPRUS, OF ACTING AS TAX HAVENS AND CRITICISES UK CROWN DEPENDENCIES AND OVERSEAS TERRITORIES

On 26th March, Ekathimerini in Greece reported on  a “hard-hitting” report which also accused 7 EU countries of acting as tax havens: Luxembourg, Cyprus, Ireland, Malta, Hungary, Belgium and the Netherlands.  The report urged EU member states to curb money laundering in the bloc by ending programmes to sell visas and passports. The report is the result of a year’s work by the Parliament’s committee on financial crime and tax evasion, and has now been adopted by the whole assembly, boosting its political weight, though it remains non-binding.  The report called for stricter rules and supervision to counter money laundering in the face of the series of scandals which hit several banks, noting that the latest overhauls maintained several loopholes in the EU legal framework.  It also urged the Commission to assess money- laundering risks posed by legal arrangements such as special purpose vehicles and non-charitable purpose trusts, especially in Britain and its Crown Dependencies and Overseas Territories.

http://www.ekathimerini.com/238910/article/ekathimerini/news/european-parliament-report-accuses-seven-countries-including-cyprus-of-acting-as-tax-havens

US ADDS MANY NAMES OF INDIVIDUALS AND ENTITIES TO IRAN SANCTIONS LIST, AND AMENDS ENTRIES FOR 2 ENTITIES AS IT CLAIMS TO HAVE DISRUPTED FRONT COMPANY NETWORK

On 26th March, OFAC issued a news release saying it had taken action against 25 individuals and entities, including a network of Iran, UAE, and Turkey-based front companies, that have transferred over a billion dollars and euros to the Islamic Revolutionary Guard Corps (IRGC) and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL), in addition to procuring millions of dollars’ worth of vehicles for MODAFL.  The action is said to have exposed an extensive sanctions evasion network established by the Iranian regime.

It says that through the IRGC-controlled Ansar Bank, the Iranian regime established a layered network of front companies based in Iran, Turkey, and the UAE to bypass sanctions, gain access to the international financial system, and exchange devalued Iranian rial for dollars and euros. Ansar Bank also used international free zones to establish front companies.

https://home.treasury.gov/news/press-releases/sm639

Details of the new and amended entries are at –

https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20190326.aspx

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