OFAC Adds Libyan SDNs; Removes IRISL Vessels

The United States Department of the Treasury Office of Foreign Assets Control (OFAC) has announced the addition of three entities to the list of Specially Designated Nationals (SDNs) designated for being owned or controlled by the Government of Libya. The sanctions imposed against Libya in February of this year, block all property and interests in property of the Government of Libya and its agencies, instrumentalities and controlled entities within U.S. jurisdiction, whether identified by OFAC or not. As such, U.S. persons are prohibited from engaging in business with any Libyan state-owned entity.

Those entities designated today include:

1. Libyan Jamahiriya Broadcasting Corporation. This entity is Libya’s state broadcasting company and owns several radio and television stations in Libya;

2. Dalia Advisory Ltd. A London-based investment firm that is 100 percent owned by the Libyan Investment Authority (LIA). The LISA was identified by OFAC as a Government of Libya entity on March 15, 2011;

3. Lafico Algeria Holdings. LAFICO is an Algeria-based subsidiary of the Libyan Arab Foreign Investment Company (LAFICO). LAFICO was identified by OFAC as a Government of Libya entity on March 15, 2011.​

In addition, to OFAC’s additions to the SDN List, OFAC has removed two vessels previously designated under the Non Proliferation of Weapons of Mass Destruction Sanctions Regulations. Both of these vessels, Mir Damad and Mir Emad, were owned or controlled by the Islamic Republic of Iran Shipping Lines (IRISL). It is unclear whether these SDNs invoked OFAC’s formal administrative process to remove their names from the list or if there were some other circumstances which lead to their removal. As readers of this blog know, a number of IRISL vessels have been placed on the OFAC SDN List, however recently they are frequently being removed from that list.

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.

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