OFAC update

Fifteen financial institutions were included in the latest list of entities subject to OFAC Civil Penalties Enforcement.The sanctions programs involved in these penalty actions included Kosovo, Iran, Libya, Burma, Cuba, and Sudan.The highest bank penalty imposed in this group of penalties was $29,000.See the full penalty report.The affected banks were:

• Arab Bank PLC - $2,450
• Banco de Chile - $5,500
• Banco do Brasil - $10,612.50
• Bank One - $5,500
• Central Carolina Bank - $3,750
• Citibank - $5,500
• Citibank on behalf of California Federal Bank - $5,500
• Comerica Bank on behalf of Imperial Bank - $29,000
• HSBC Bank USA - $5,500
• Hammi Bank on behalf of Pacific Union Bank
• International Commercial Bank of China - $9,748.31
• JP Morgan Chase Bank - $9,748.31
• JP Morgan Chase Bank - $18,094.40
• La Salle Bank N.A. - $3,050
• Lee Bank - $16,500
• Nordea Bank Finland, PLC on behalf of Christiania Bank - $16,500

The transactions that were the subject of the penalties dated back as far as 1998, but some were as recent as 2003 and 2004.

Libyan Amended General License

In order to clarify and further ease the remaining transportation-related sanctions against Libya, OFAChas issued an amended general license for new transactions, ? 550.575 of the Libyan Sanctions Regulations, 31 C.F.R. Part 550. The change from the general license issued on April 23, 2004, appears in paragraph (b)(3) of the amended general license. Previously, all transportation-related transactions remained prohibited, except for those expressly authorized by ? 550.574, the general license for travel to Libya. The amended general license authorizes all transportation-related transactions, except for those transactions specified in paragraph (b)(3), which remain prohibited. Two examples of the changes effected by the amended general license are: (1) U.S. air carriers may now operate all-cargo charters to Libya; and (2) Code-sharing between U.S. and third-country air carriers on U.S.-Libya service is now permitted.