SDN Moves: OFAC strikes back, Trouble in the Congo, More Kony Womp Womp

A nice turn of pace for SDN activities. Sorry for the delay again.   Counter Narcotics Today OFAC designated a money-laundering cell operating between Peru and Spain (see, it was on purpose I delayed posting until today!…right). Of course, no designation can go without an Analyst Notebook chart for your viewing pleasure. Press release details are moderate, but given the SDNT context it is clear it is for transmission of proceeds from Colombia to Spain. Given the designated’s client list, he appears to be closely associated with the FARC and this goes straight to the point of FARC penetration of Europe via West Africa. I did a study a few years back on this and it seems to be the onward trend. That’s mainly notable because during my briefing I made someone cry… Manuel Aguirre Galindo, an SDN under the SDNTK program and a senior leader for the faltering AFO cartel was confirmed arrested Saturday. Good ole Manny was a senior level AFO member who allegedly oversaw a large financial aspect of their operations. Thus his arrest is a good notch on the belt for any OFAC and AML program. And is it just me, or has AFO been taking the biggest beating lately of all the cartels? Alternately, Stratfor tackles the question of whether the Zetas are really on their way out. They seems to think the Zetas will be around a little longer. I’m not going to object in the short term, but I don’t believe the Zetas will see long term existence. I did an article on why I think this earlier this year.   Counter-Terrorism This week seems to be a trade off between narco and terror. When one heats up, the other pipes down. However we did drone two senior members of al-Shabaab (not designated). ‘Murrica. The UN designated Muhammed Jamal al-Kashef, but he had previously been designated under OFAC and thus should already be in the filter.   Country Programs War crimes poster-boy and Facebook one-hit wonder Joseph Kony watch out, some 18 Bravos have bullets with your name on it. Kony is designated under SDGT. For those interested, State released a Q&A background on the P5+1 negotiations for Iran. I personally haven’t read it and probably won’t for a few days…or ever. But feel free to comment and pique my interest. DRC designated group M23 is starting more trouble in the Congo. Negotiations broke down and now they are getting smacked around by the military of the DRC. Reports are positive but I’m sure the group, or another equally bad one, will retreat into Rwanda and find itself fighting again a year from now. It’s unfortunate as that the talks broke down due to disagreements on amnesty. For these conflicts, Disarmament, Demobilization and Repatriation (DDR) ops are some of the most difficult issues. Having the rebels voluntarily disarm is the best way to guarantee future stability, yet the more brutal a group is the harder it is to forgive. Separating the bad apples from those that can be successfully repatriated is difficult, but when the bad apples are doing the talking its almost impossible to both seek peace and justice simultaneously....

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SDN Moves: Snowden leaks, peace talks and not so funny clowns

With OFAC back in action this week, we’ll see how designations pick up in the next couple of weeks. I’m sure OGT is playing catch-up but a designation package isn’t something that’s produced overnight. So in all likelihood everyone is just going to pick up where they left off. As for the world, it’s been another awfully quiet week. A lot of excitement around Iran negotiations, some very weird pre-peace talks in Syria that are most likely fruitless.   Counter-Terrorism Hassan Ghul, a.k.a. Mustafa Hajji Muhammed Khan, an SDGT was confirmed killed by documents released to the Washington Post in the Snowden leaks. Yeah, this happened.   Counter-Narcotics Francisco Rafael Arellano Felix, one of the AFO brothers (but not an SDN…he may have been de-listed but I’m still searching the federal register for historicals) was killed by a sicario in a clown costume. Bonus points for style. The linked article also has a few names of close associates that it would be wise to screen for. Chances are most people at the party have some affiliation with AFO. Now the big question is who ordered the hit? A senior member of the Sinaloa cartel, Jose Fidel Nunez Meza, was arrested. He is not designated and neither are his brothers, also listed in the article. Nonetheless, they are probably good names to add to the filter.   Country-Programs With Iran talks up, there is a lot of questions about acceptable outcomes of the negotiations. Some want Iran to completely dismantle their nuclear program, which I don’t think is an acceptable outcome for Tehran. Ostensibly, U.S. priorities are to ensure that Iran does not have a nuclear weapons capability, so a good negotiating strategy would look to have Iran give up the requisite amount of tech to ensure they can’t have nukes while still being able to retain a peaceful energy capability. In probably the most interesting article I read last week, it seems that the strategy that gives the most marginal utility is to focus on them relinquishing their medical isotope projects. It’s a somewhat statistics heavy article but it reads well and gives a lot of perspective to what the talks will look like. Does anyone know what is up with these proposed peace talks in Syria? I have no clue how that would even work. The FSA, rebellion in general, the government of Syria and all of the members of the Arab League would have to get together to pow-wow, all while being baby-sat by a stability wanting mother (the U.S.) and the worlds equivalent of a drunk and deceiving father (Russia). Count me out....

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SDN Moves: Profile of the IRGC head, SDN Successors, Designation-less Week

I’m sorry everyone, but this week’s SDN moves is kind of boring. A big reason is because just in case you’ve been under a rock, OFAC is on the Congressional Incompetence plan and nobody is lighting the fires of Gondor in the annex. Or designating anyone. But a silver lining is that I’m sure a lot of you have gotten to go home on time and not work after hours updating and testing the filter.   Terrorism Mullah Sangeen Zadran, who was expertly droned several weeks back has been succeeded by Bilal Zadran. Bilal is Sangeen’s nephew, continuing on the trend of familial leadership in the Haqqani network.   Narcotics A very quiet week on the Narco front. To my knowledge, no SDNs were killed, captured or embarrassed themselves too much. Not necessarily SDN related, but certainly post-worthy is the closure of the Silk Road. It looks like Bitcoin Bro wasn’t the smartest kid on the block, despite making $80 million in commissions.  However there are other illicit markets out there using cryptocurrencies. Albeit certainly humorous at times (” Do you sell organs/ No just regular pianos/ what are you looking for?”), this AMA of the leader of another illicit online trading forum provides some very interesting insight into the concerns of these businesses, how they operate and the motivations of starting them up. Nonetheless, I hope this is the last time I ever post a link to reddit.   Country Programs Trucking right along, it looks like a lot of the fervor of talks between Rouhani and Obama is starting to settle down to the normal pessimistic crawl. However the New Yorker did an exceptional expose on Qassem Sulameini, the head of the IRGC and an SDN. If there is one article I would suggest you read this week, this would be it. Also, hot off the presses from a friend. Reuters has a report on the Myanma jade industry. Remember, while most trade has been GL’d out, trade in goods under the JADE ACT (jadeite, etc.) are still prohibited as well as dealing with any SDNs. I haven’t read the report (as I said, I literally got it right before I hit the publish button) but I trust my friend’s (another OFAC alum) judgement. So, that about wraps it up. Have a great...

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OFAC tired of reacting to every earthquake ever…adds two new GLs to Iran program

In a very good move, OFAC issued two general licenses that should both assist in clarifying and bolstering a passage of the CFR as well as substituting for the possibility of a plethora of other general licenses in the future for humanitarian crises in Iran.   General License E   Generally when a tectonic plate is named after your country, it’s bad news. It’s even worse when that isn’t the only fault line to run through you. In a year long period we saw three earthquakes and in this past decade we have had about 30,000 deaths from earthquakes in Iran. But even for earthquakes where fatalities may not be particularly high, property damage is excessive. This means destruction of infrastructure, clogging of critical supply routes (think of how barren an NYC grocery store would be if the GW Bridge and Lincoln Tunnel collapsed), loss of homes, possible inaccessibility to well water, the list of misery goes on. Without relief, it is quite possible more people will die from starvation, disease and the elements than were killed by the event itself. A good way to mitigate the misery is through humanitarian donations, which is  of itself a very broad category. For the actual donation of goods, 31 CFT 560.201 (b) covers that: (b) Humanitarian donations. The prohibitions of §§ 560.204 and 560.206 do not apply to donations by United States persons of articles, such as food, clothing, and medicine, intended to be used to relieve human suffering. What this passage does not cover however is the multitude of other non-profit activities that are required for the relief of human suffering. 210(b) only covers the donation of these articles but does not cover the exportation of financial services to provide funds for humanitarian operations. For instance, lets say a bridge is down on a critical supply route and a temporary bridge needs to be put up. The Iranian army is too busy conducting terrorism and human rights violations somewhere else and thus can’t get the appropriate bridging equipment on site, and thus to relieve human suffering an NGO has to contract out to have a temp strung up. This would generally warrant a specific license if it is for earthquake relief and typically instead of OFAC tackling tons of specific licenses, they will issue a general license covering that specific earthquake. The problem is, issuing a GL takes time and OFAC still has to deal with the initial wave of licenses. Instead, they have issued General License E which covers all future natural disasters. Not only does this relieve the burden on OFAC, but it also allows NGOs to swing into action quicker. Interestingly, GL E has also worked in some language that was very similar to one of the earlier Burma GLs that supports both democracy and peace building. In fact, the language in paragraph (a)(1) of GL E is almost the same word-for-word for the language in GL 14-C under the Burma program, while the language in paragraph (a)(4) is very similar as well.   General License F     As for the other general license issued, GL F now explicitly authorizes the exportation and importation of financial services to and from Iran for sports games. If anyone remembers, there was a bit of controversy regarding an Iranian soccer ref and this is the clear cut response from OFAC. Part of this stems from how one could interpret 31 CFR 560.554, particularly the portion that reads: …the exportation, reexportation, sale, or supply of services directly related to the sponsorship by a U.S. person of a public conference or other...

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SDN Moves: Iran Designations, Trevino found guilty, SDGTs KIA and why not to have a cartel member in the family

Because the fun don’t stop until the big man says so… Yesterday OFAC released a handful of designations under the Iran tag, but no press release forthcoming.   This is also the first time that an [IRAN] designation has had an annotation stating its subject to secondary sanctions. While OFAC doesn’t explicitly come out and explain the tag, its no doubt in reference to the IFCA provisions, particularly section 2(i). Happily, OFAC has modified their own proprietary filter to reflect these changes on the small sample I checked (okay, n=2…it’s Friday and I’m apparently a lazy blogger) and warn users of the threat of secondary sanctions. The only entities exempt from these secondary sanctions are those that were designated “solely pursuant to Executive Order 13599,” i.e. those banks that are blocked for the sole nature of being owned or controlled by CBI (reflected appropriately in their own filter). On another note, Erich at Sanction Law noted that OGT has been all quiet on the east-middle-eastern-ish front (okay, give me a break, I’m trying to mix Remarque and Iran and its just not working) for almost exactly two months since some IFCA designations and three months since regular Iran designations. Mr. Ferrari thinks the dearth could be political, so does this designation package signal a swing back to the stick-over-carrot approach? Or is summer vacation just finally finished and foreign policy continues as usual? On the Mexico front, things are going swimmingly…so long is you aren’t a bro of a kingpin. A literal bro that is. Miguel Trevino’s brother was sentenced to 20 years for money laundering as Z-40 waits for his own trial to begin. Alberto Carillo Fuentes, brother of Vincente Carillo Fuentes was also arrested in Mexico. Neither individuals are designated but both were engaged in cartel operations. Borderland Beat does report that Alberto had taken control of the New Juarez Cartel1 after Vincente retired, but that’s unconfirmed at best. As much as it pains me to cite a Huffington Post article (what’s next, USAToday?), even U.S. officials aren’t exactly sure of Alberto’s role. Most likely the reason why he isn’t designated yet. Moving back to the MENA region, SDGT Sangeen Zadran is suspected of taking a dirt nap. The report in unconfirmed and sometimes these guys have a habit of rising from the dead. Just because the ISI says it’s so doesn’t make it accurate. Particularly because this guy is part of the Haqqani network.   1Super interesting article by the...

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