Wednesday, October 12, 2011

HAVE YOU CHECKED THE IRANIAN NAMES IN THE NEW OFAC SANCTIONS LIST AGAINST YOUR CLIENT BASE ?


The designation, by OFAC, of four senior officials* in the Iranian Revolutionary Guard Corps-Qods Force [IRGC-QF], due to their reported involvement in the failed attempt to commit an assassination and other terrorist acts in the United States, and elsewhere, is not just a reason for you to check these names against your client records. There's more to the compliance problem, and it is not limited to US-based financial institutions.

Treasury has correctly noted that the IRGC-QF is involved in providing material support to Hamas, the Palestinian Islamic Jihad [PIJ], Hizballah, and the PFLP. The individuals operate under one or more of  several aliases, and if they were supporting this operation, they probably have been involved in the organisation of international terrorist plots elsewhere.

Therefore, wherever you are, check the names thoroughly, and of course also check the US-based individual who has been formally charged with the crime; he is also on the 11 October sanctions list.
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*http://treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20111011.aspx

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