Last Friday the United States Department of the Treasury Office of Foreign Assets Control (OFAC) placed on the Specially Designated Nationals list, otherwise referred to as the OFAC SDN List, a number of individuals and entities pursuant to the OFAC Kingpin regulations.

The targeted parties, making up the New Ansari Money Exchange, are accused of being at the center of an unofficial network of individuals, money exchange houses and other businesses operating throughout Afghanistan and in the United Arab Emirates. According to Treasury, The New Ansari Money Exchange transfers money related to narcotics trafficking activities to Dubai subsidiaries, Green Leaf General Trading LLC and Al Adal Exchange, which then in turn transfers such money through the U.S. and international financial systems.

It is also believed that the New Ansari network have laundered money for other alleged narcotics traffickers on the OFAC SDN List such as Haji Azizullah Alizai and the Haji Juma Khan Organization. For those unfamiliar with these individuals, Haji Azizullah Alizai is allegedly a major heroin trafficker and supplier in Southwest Asia and the Middle East, while the the Haji Juma Khan Organization is an international opium, morphine, and heroin trafficking organization. The Haji Khan Organization is believed to be based in the border regions of Iran, Pakistan and Afghanistan.

Due to these designations, U.S. persons are prohibited from conducting financial transactions with these individuals and entities, and any assets the designees may have under U.S. jurisdiction are frozen. The investigation that led to these designations included the participation of the Afghan Threat Finance Cell (ATFC), an organization that collects, analyzes and disseminates relevant financial intelligence on individuals and organizations involved in financing the insurgency.

Those individuals designated pursuant to OFAC’s latest actions are thought to play key roles in the New Ansari Money Exchange, including Haji Abdullah Barakzai Ansari, the founder of the New Ansari Money Exchange; Haji Mohammad Khan, the manager of the New Ansari Money Exchange; Haji Mohammad Jan, the day-to-day manager of the New Ansari network; Haji Noorullah, a stakeholder and director of the New Ansari Money Exchange; Haji Mohammad Noor, the manager of the New Ansari Money Exchange subsidiaries in Dubai; and Haji Mohammad Rafi Azimi. In addition to these individuals, cash couriers Eissa Jan Haji Abdul Qayoum and Rahmatullah Mohammad Afzal were also designated. According to OFAC, Rahmatullah Mohammad Afzal is believed to have transferred $94 million from Afghanistan to Dubai for the New Ansari Money Exchange.

Since June of 2000, OFAC has designated more than 900 businesses and individuals linked to 87 drug kingpins internationally.

Often times in an OFAC SDN List removal matter, OFAC is looking for specific information. For example, one of the main items OFAC seeks information on is the existence of any shared accounts held by an individual or entity with a party on the OFAC SDN List. Therefore, it is possible that one or more of the designated parties here holds some sort of asset or account that is shared with a party on the SDN List. Thus, before removal of the SDNTK designation can take place the termination of that shared relationship will have to take place.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com.