CHEMICAL WEAPONS PROCUREMENT FOR SYRIA

In June, another research project from C4ADS which asks how a regime under such a heavy international sanctions regime can acquire the supplies needed to manufacture chemical weapons, and saying that it has identified possible routes for continued procurement of materials that support the Syrian chemical weapons programme.  It deals with what it refers to as the Handasieh Network (aka Syria’s General Organization for Engineering Industries) which, it points out, is more than just one Syrian company – there are at least 14 subsidiaries operating directly under it that produce everything from steel to renewable energy to pencils.  If these companies are 50% or more owned by Handasieh, they too are legally sanctioned by OFAC.  However, only one of Handasieh’s direct subsidiaries, the Syrian Arab Electronic Industries Company (Syronics), has been explicitly sanctioned by OFAC, while 2 additional entities that share identifiers with one of Handasieh’s subsidiaries have also been designated.  These unsanctioned subsidiaries represent possible avenues for sanctions evasion and chemical weapons procurement.

https://c4ads.org/blogposts/2019/6/25/the-handasieh-network

Handasieh+and+subsidiaries

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SOLICITORS: ‘SIGNIFICANT’ RISE IN MONEY LAUNDERING REPORTS

On 26th July, the Law Society Gazette reported that the Solicitors Regulation Authority (SRA) in England & Wales has seen a 43% rise in reports of possible money laundering.  In the first 9 months of 2018 it received 218 money laundering reports, compared with 152 in the same period in 2017, a ‘significant’ increase according to the SRA.  This information is contained in the SRA report: “Upholding Professional Standards 2017/18”.

https://www.lawgazette.co.uk/news/significant-rise-in-money-laundering-reports-/5071147.article

The report is available at –

https://www.sra.org.uk/sra/how-we-work/reports/upholding-professional-standards-2017-2018.page

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US $100 BILL ON THE RISE

A post on the IMF Blog on 25th July says that a curious thing has happened in US currency: the $100 bill recently overtook the ubiquitous $1 bill in circulation volume, for the first time in history.  In other words, the most valuable banknote in the US became the most widely circulated- and roughly doubling in volume since the global financial crisis.

https://blogs.imf.org/2019/07/25/us100-bill-on-the-rise/

https://www.imf.org/external/pubs/ft/fandd/2019/06/what-makes-the-US-100-bill-so-popular-currency.htm

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imf

REFORMING US SECONDARY SANCTIONS: WHAT’S WRONG THAT CAN BE RIGHTED?

On 22nd July, Arent Fox published an article in which members of its Export Controls & Economic Sanctions team published analysis in WorldECR that identified problems with the application of secondary sanctions.  It explains that US secondary sanctions are the sanctions that the US can apply to wholly non-US actors in wholly non-US transactions of which the US administration disapproves.  Numerous statutory and executive orders provide authority for imposing secondary sanctions for transactions involving multiple countries, primarily Iran, Russia, North Korea and Venezuela, and involving a wide range of activities, including violating human rights.  It has a number of headings and topics –

  • the triggers for secondary sanctions are unclear: what is a ‘significant transaction’?;
  • there’s no one to ask. Non-US persons who are not subject to US jurisdictions cannot apply to OFAC for a licence;
  • secondary sanctions are imposed in a discriminatory fashion;
  • it is not merely a question of doing business with Iran or doing business with the US: an entity on the SDN List will have problems doing business in its own country, due to risk-averse positions taken by banks and other companies;
  • there often is no warning;
  • getting off the SDN list is very difficult and takes time and resources;
  • secondary sanctions do not usually trigger standard force majeure clauses in contracts and agreements; and
  • secondary sanctions commercially favour the non-compliant: the companies who step in are those that do not care about US foreign policy or the US market.

https://gallery.mailchimp.com/31e15e5fee7b5a6208b646806/files/30693a7c-d1c1-46d7-9814-b0051f95ceb5/WorldECR_Arent_Fox_20190717.pdf

 

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at https://www.buymeacoffee.com/KoIvM842y