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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General License 18 pretty much made official, a look-back on the BSR

I didn’t post on this until now because it isn’t all that urgent. However, last night the White House issued an unnumbered E.O. repealing the ban on imports from Myanmar (Burma). This still excludes the items covered under the JADE act. In practicality, nothing has changed. OFAC issued general license 18 almost a year ago. The general license was a handy tool for negotiations as that should the situation in Yangon deteriorate, OFAC could quickly revoke the general license and return to enforcing the original regulations. Congress allowing the ban to expire signals trust in Myanmar’s progress. This event does offer us a time to reflect on Congress’ role with the Burma program. Allowing the ban to expire is a traditional tactic, so last nights actions shouldn’t have come as a surprise to anyone watching the hill. More thought provoking is the way that sanctions actually came about against Myanmar. The program initially saw its genesis in 1988 after the ruling junta cracked down on a series of protests…you know…in the typical way of warning shots above the legs. For those that believe in coincidence, you might note that the protests were called the 8888 Uprisings because they were staged on 8 August, 1988. So literally, we lifted the ban on imports 25 years after the catalyst that started the program (the administration may want to play this down however; I don’t think the symbolism would go over well with Human Rights Watch). Congress’ reaction to the resulting coup would be indicative of a trend for the entire course of the program. Instead of engaging OFAC from the beginning, they tagged a few amendments onto the Customs and Trade Act of 1990 and suspended arms imports in 1993. Congressional and executive action thereafter came in bits and pieces, including several E.O.s and finally the Jade Act. It was never willing to fully sanction the country in one large stroke, much like we did to Sudan and with the ITR (albeit we sure followed that with a wallop). My analysis is, that while sanctions were necessary and eventually successful, Myanmar became the punching bag for the House and Senate Foreign Affairs Committees (known in D.C. as the HFAC and SFAC). Because neither of them were actually involved in any real funding programs (including aid packages to other countries), the committee was more a collection of sinecures and Myanmar legislation was a great way for the members to stand up and say they were doing something great for human rights. Of course, it helps that legislation like this is easy to push through the floor (sounds familiar for some of today’s sanctions maybe?) The Burma program has always been one of the more interesting programs for me. It was a very nuanced program that was often misunderstood, and I think much of that came from the haphazard way in which it was constructed on the hill. But for its part, OFAC executed it with exceptional professionalism and I have plenty of memories of walking people through the regulations. I was delighted to see political change and be a part of the lifting of the sanctions through general licenses and have huge hopes for the country in the future. There are many services that still need to be addressed and I think the next steps would be a favorable licensing policy (or another GL similar to GL 19) to allow interactions with certain entities to make those services...

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