The United States Department of Treasury Office of Foreign Assets Control (“OFAC”) added the Free Life Party of Kurdistan to their list of Specially Designated Nationals (“SDN”). As such, the Free Life Party of Kurdistan is to have all their property and interests subject to U.S. jurisdiction blocked. In addition, U.S. persons are prohibited from engaging in transactions with the Free Life Party of Kurdistan.

According to “Wikipedia”:

“The Party for a Free Life in Kurdistan (Kurdish: (پارت ی بۆ ژیان ی ازاد ی له‌ کوردستان or Partî Bo Jîyanî Azadî la Kurdistan) or PJAK is a militant Kurdish nationalist group based in northern Iraq (southern Kurdistan) that has been carrying out attacks in the Kurdistan Province of Iran and other Kurdish-inhabited areas.

PJAK is a member of the Kurdistan Democratic Confederation (Koma Civakên Kurdistan or KCK), which is an alliance of outlawed Kurdish groups and divisions led by an elected Executive Council. The PKK, described as a terrorist organization internationally by a number of states and supranational organizations, including the USA, NATO and the EU, is also a member of KCK. A recent New York Times article stated that PJAK and PKK “appear to a large extent to be one and the same, and share the same goal: fighting campaigns to win new autonomy and rights for Kurds in Iran and Turkey. They share leadership, logistics and allegiance to Abdullah Ocalan, the PKK leader currently imprisoned on İmralı.”

The Free Life Party of Kurdistan was designated under the Terrorism Sanctions Regulations; a particularly broad sanctions program that goes as far as prohibiting donations normally allowed under section 203(b)(2) of the International Economic Emergency Powers Act (“IEEPA”), as well as providing for unilateral medical and agricultural sanctions. The Terrorism Sanctions Regulations were created by Executive Order 13224.

As always it is important to remember that these designations have a very real impact on U.S. persons, particularly business owners. Please make sure to check the SDN lists regularly to make sure you are not involved in any type of transaction with an SDN; the consequences could be devastating.

If you feel that you may have violated any of the U.S. sanctions regulations please contact the author by email at info@ferrari-legal.com

The author of this blog is Erich C. Ferrari, an attorney in Washington, DC, who specializes in Sanctions Law and White Collar Criminal Defense. If you have any questions please email him at info@ferrari-legal.com