Tag: Iran

Weekend Reading: A Time to Attack

a time to attack

What should we do about the nuclear weapon program in Iran? The country is not complying with the Treaty on the Non-Proliferation of Nuclear Weapons. Iran has four main sites being used to create weapons-grade uranium. The country has stopped short of further purifying the uranium to the concentration needed for a bomb. But once it decides to, Iran can produce the uranium needed for a bomb in two to six months.

Besides the uranium, Iran needs to develop the weapon and means of delivery. The weapon is still a year away and the delivery method could be longer than that.

But once Iran gets the uranium it’s game over. Once the uranium in produced we lose the way to track it.

I didn’t know any this last week until I picked it up from Matthew Kroenig’s A Time to Attack: The Looming Iranian Nuclear Threat. The book’s publisher sent me copy to review and I was looking to learn more about the Iran nuclear issue.

Iran is spinning centrifuges to enrich uranium. There is no civilian purpose for this uranium. The only purpose is to create a nuclear weapon. Iran is working on ICBMs. No country has placed conventional weapons on an ICBM. The only use has been to mount a nuclear device to launch across vast distances.

We know where the four key sites are located. The toughest is Qom which is built into the side of a mountain and protected by almost 300 feet of rock. No really, google the Qom Uranium enrichment facility. It’s right on Google maps.

Matthew Kroenig offers a few possible courses of action. There is only one that he thinks will work: Attack once Iran passes the point of no return. It’s not a good approach and does not have a good outcome. But the other outcomes are worse.

Would any other country believe that the US would go to war with a nuclear-armed Iran, if the US was not willing to go to war with a nonnuclear Iran. Once Iran has a nuclear weapon, the rest of region will start their own programs out of fear of Iran and the lack of faith in the US.

Yes, it has to be the US. Israel does not have a bunker-busting bomb powerful enough to destroy the Qom facility or even the lesser protected facility at Natanz. Even for the US, the B-2 bomber is the only aricraft capable of delivering the Massive Ordnance Penetrator bomb.

Kroenig puts together well reasoned arguments in an easy to read book. It leaves even a liberal dove like me agreeing with his position.

New Lists to Check for Bad Guys

bad guy

If you conduct business overseas or have foreign investors in your funds, you are checking the various block persons lists to ensure you’re not working with bad guys. (You are checking, right.) The Office of Foreign Assets Control (“OFAC”), of the U.S. Department of the Treasury, has created two new lists: the Foreign Sanctions Evaders List and the Blocking Property of Additional Persons Contributing to the Situation in Ukraine.

Foreign Sanctions Evaders List

The FSE List implements Executive Order 13608 by identifying non-U.S. persons and entities that have engaged in conduct evading U.S. economic sanctions with respect to Iran or Syria.  The FSE-listed individuals or entities are not necessarily located in Iran or Syria.

You are generally prohibited from all transactions or dealings, direct or indirect, involving persons or entities identified on the FSE List related to any goods, services, or technology (i) in or intended for the United States, or (ii) provided by or to U.S. persons, wherever located.  However, unlike the OFAC Specially Designated Nationals List, the new FSE List does not require blocking of property and reporting of transactions with FSE-listed entities.

OFAC has elected to maintain a separate FSE List rather than include the FSE entries on the Specially Designated Nationals List.  That means you need to screen against both lists. Most likely, you are using software or a third-party service provider, so check to make sure the FSE List was added to the screening protocol.

Blocking Property of Additional Persons Contributing to the Situation in Ukraine

By Executive Order on March 20, 2014, President Obama put in place new restrictions on companies and individuals that operates in sectors of the Russian Economy that would support the Russian Federation’s annexation of Crimea. It’s an expansion of 13660 and 13661.

So far, the orders have brought sixteen Russian government officials, members of the Russian leadership’s inner circle, and a Russian bank into the sanctions regime. Bank Rossiya (ОАО АБ РОССИЯ) is the personal bank for senior officials of the Russian Federation.

OFAC has added the blocked persons to the Specially Designated Nationals List. I received a notice that my vendor has already included the names in its database.

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Image of villain is a caricature by J.J. McCullough
cc by sa

Iran, Tuvalu, and Oil

Anyone who works with sanctions monitoring most likely hates ships. Their names are so common that the ships’ names routinely cause false positives. (My software has a button to exclude ships’ names, but I often forget to activate that feature.) Now the Iranian oil sanctions program is highlighting some issues with ships.

The tiny Pacific island nation of Tuvalu is prepared to re-flag a fleet of National Iranian Tanker Co. vessels to operate under Tuvalu’s ship registry.  From a personal perspective, it will likely mean more ship names in the databases. Fortunately, my company doesn’t deal with ships so it will only affect me when I forget to select the right option.

On a global scale, it may be an effective way to hide ownership and get cash to Iran. There is still the problem of moving the cash through the global financial system.

Rep. Howard Berman, the ranking member of the House Foreign Relations Committee wrote a letter to Willy Telavi, prime minister of Tuvalu, to cancel the registry.

It is my understanding that the Government of Tuvalu has permitted the National Iranian Tanker Company (NITC) to reflag as many as 22 vessels under the Tuvalu ship registry, allowing them to remain under NITC ownership and continuing to transport Iran’s crude oil exports. This has the effect of assisting the Iranian regime in evading U.S. and EU sanctions and generating additional revenues for its nuclear weapons program and its support for international terrorism.

It would be profoundly disappointing to me if your government has acted in contravention of the broad international coalition that is working together to use peaceful means, including economic sanctions, to change the threatening behavior of the Iranian regime.

Prior to selling its soul to Iran, Tuvalu was mostly known for its strong position on global warning. The county is small and flat. At just 26 square kilometers Tuvalu is the fourth smallest country in the world, larger only than the Vatican City at 0.44 square kilometers, Monaco at 1.98square kilometers and its neighbor Nauru at 21 square kilometers. At its highest, Tuvalu is only 4.8 meters above sea level. A dramatic rise in sea level could make the country inhabitable.

Why would such an environmentally fragile country help a rogue nation? Tuvalu has been looking for a place to re-settle its inhabitants once sea levels rise. It seems unlikely that they would choose Iran for resettlement. I would assume it comes down to cash. I suspect Iran offered a big pile of cash, with some of it going directly to select Tuvalu officials.

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Image of Iranian and Tuvalu flags courtesy of crossed flag pins.com

Real Estate and OFAC Compliance

650 fifth avene

The tale of 650 Fifth Avenue is one that should be closely watched by compliance professionals dealing with real estate. Last year, the Department of Justice filed a forfeiture proceeding against a 40% interest in the property held by the Assa Corporation. They recently filed a forfeiture proceeding against the other 60% held by the Alavi Foundation.

The Amended Complaint alleges that the Alavi Foundation has been providing numerous services to the Iranian Government and transferring funds from 650 Fifth Avenue Company to Bank Melli, a bank wholly owned and controlled by the Government of Iran. The Amended Complaint alleges that the properties are forfeitable as the proceeds of violations of the International Emergency Economic Powers Act, 50 U.S.C. §§ 1701 et seq., together with Executive Orders and United States Department of Treasury regulations, and as property involved in and the proceeds of money laundering offenses.

Now the tenants are in the position of having been making rent payments to the Iranian government. This may not result in any criminal or civil sanctions, but the names of those tenants are being dragged through the muck. The same is true for the property management company.

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Government Seizes 650 Park Avenue

650 fifth avene

According to the Wall Street Journal, the United States Attorney for the Southern District of New York has filed a forfeiture proceeding against 650 Fifth Avenue in New York.

In its press release: United States files civil forfeiture action against ASSA corporation’s interest in Manhattan office tower (.pdf), the DOJ claims that a 40% interest in the building is held by the ASSA Corporation which is acting as a front for Bank Melli. The Government of Iran controls Bank Melli and ownership is considered an export under the Iraninan Transaction Regulations (Title 31 CFR, part 560)

This post originally appeared in one of my old blogs: Real Estate Space.