by Steven Pelak and Michael O’Leary
On Wednesday, the U.S. Department of Justice (DOJ) announced that Geoffrey Shank, has been sworn in as the new Washington Director of the International Criminal Police Organization (INTERPOL). See http://www.justice.gov/interpol-washington/pr/fbis-james-comey-swears-new-interpol-washington-director. As Director, Mr. Shank will act on behalf of the Attorney General as the official U.S. representative to INTERPOL. He previously served as the Deputy Director of Washington INTERPOL and has had a distinguished career within the U.S. Marshal’s Service spanning more than 25 years.
Through their energy, initiative, and drive, individuals do matter in law enforcement. The appointment of a well-respected and vigorous law enforcement official to the top post in the U.S.’s delegation to INTERPOL is a clear signal that efforts aimed at greater cooperation between U.S. and foreign law enforcement agencies will likely accelerate in the immediate future. Because of the particular importance of international cooperation and assistance by law enforcement in export controls and trade sanctions investigations and enforcement matters, Mr. Shank’s appointment will have particular importance for individuals and companies facing cross-border compliance issues in these areas.
by Jeremy Paner
On November 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the designations of Altaf Khanani Money Laundering Organization (Khanani MLO) and Al Zarooni Exchange pursuant to Executive Order 13581, the transnational criminal organization designation authority. OFAC designated Khanani MLO as a transnational criminal organization and concurrently listed Al Zarooni Exchange based on its being owned or controlled by, or providing support or services to Khanani MLO. Al Zarooni Exchange is located in Deira, Dubai, an international financial center for Iran. It is therefore not surprising that Khanani MLO provides money laundering services for associates of Hizballah, according to OFAC.
These are the second recent OFAC designations in the past few weeks based on the provision of money laundering services. On October 7, 2015, OFAC designated Honduran international narcotics trafficking money launderers and several of their prominent businesses, including Banco Continental pursuant to the Kingpin Act. While the Specially Designated Nationals (SDN) List and the Sectoral Sanctions Identification (SSI) List contain many banks, Banco Continental is the first bank designated pursuant to the Kingpin Act. The immediate effect of this designation was quite clear, as the Government of Honduras placed Banco Continental under the management of a government-appointed liquidator in response to the listing. Continue reading
by Steven Pelak, Jeremy Paner, and Gwen Green
On November 13, 2015, Ahmad Feras Diri, of London, was arraigned for his alleged involvement in a conspiracy to illegally export laboratory equipment, including items used to detect chemical warfare agents, from the United States to Syria. The arraignment comes almost three years after Mr. Diri was originally indicted on the charges in November 2012. The arraignment highlights the efforts and distances which U.S. law enforcement will go in pursuit of those assisting the military regimes of Syria and Iran.
According to the indictment, from 2003 until November 20, 2012, Mr. Diri; his brother Mowea Diri, a citizen of Syria; d-Deri Contracting & Trading, a business located in Syria; and Harold Rinko, a U.S. citizen and 73-year old Pennsylvania resident, conspired to export EAR-controlled laboratory equipment from the United States through third party countries to customers in Syria without the required U.S. Commerce Department licenses. Some of the items allegedly exported include: a portable gas scanner used for detection of chemical warfare agents and a handheld instrument for field detection and classification of chemical warfare agents and toxic industrial chemicals. Pursuant to the Export Administration Regulations (“EAR”), a license is required to export and reexport to Syria all items subject to the EAR, other than limited and certain categories of food and medicine.