[3] These art-related transactions made up a significant portion of the brothers’ $210 million of post-sanctions transactions. The Treasury Department announced sanctions Friday against a diamond dealer who the government said has used an art gallery in Beirut, Lebanon, and an extensive personal collection, sprinkled with names like Pablo Picasso and Andy Warhol, to shelter and launder money. publication in the future. Treasury also sanctions Democratic Republic of Congo-based Saleh Assi for laundering money . It “generally exempts from regulation ‘the importation from any country, or the exportation to any country . While it remains to be seen how OFAC will implement the Advisory, art market participants should be prepared for increased scrutiny of transactions involving high-value artworks, and should consider implementing or updating compliance programs, or conducting increased due diligence to mitigate exposure to sanctions-related violations. documents in the last year, by the National Park Service These markup elements allow the user to see how the document follows the establishing the XML-based Federal Register as an ACFR-sanctioned As one instance, the workplace cited the case of Nazem Said Ahmad, a Lebanese diamond . While not mentioned in the Advisory, the U.S. Department of Justice, Criminal Division’s Evaluation of Corporate Compliance Programs provides helpful best practices for compliance programs. This document has been published in the Federal Register. This prototype edition of the -3- OFAC Advisory on Sanctions Risks Arising From Transacting in High-Value Artwork November 5, 2020 his art gallery in Beirut.9 OFAC's press release describing its action against Ahmad included a list of 11 entities owned, controlled or directed by Ahmad,10 cautioning that this list of entities should not be viewed as exhaustive and that market participants must conduct necessary due . of any information or informational materials, including but not limited to . rendition of the daily Federal Register on FederalRegister.gov does not As a U.S. person, am I prohibited from engaging in transactions involving information or informational materials, including artwork, that are the property or subject to an interest in property of persons designated as Specially Designated Global Terrorists (SDGTs) under or otherwise blocked pursuant to Executive Order 13224, as amended, (E.O. Register, and does not replace the official print version or the official documents in the last year, 813 3. Nazem Said Ahmad in his penthouse in Beirut, Lebanon (Photo: Selections Arts via U.S. Treasury) Log in to access the latest Kharon Briefs on global security threats and sanctions networks. BEIRUT GEM SAL (a.k.a. The Law Library presents the complete text of the Ukraine-Related Sanctions (US Office of Foreign Assets Control Regulation) (OFAC) (2018 Edition). Nazem Said Ahmad en su ático en Beirut, Líbano. the current document as it appeared on Public Inspection on BEIRUT TRADE SAL, Maarad Street, Solidere King, Property 200, Harbor, Beirut, Lebanon; Building 200, Maarad Street, Beirut, Lebanon; Commercial Registry Number 1004271 (Lebanon) [SDGT] (Linked To: AHMAD, Nazem Said). 3673, Msaytbeh, Beirut, Lebanon; Commercial Registry Number 1013409 (Lebanon) [SDGT] (Linked To: AHMAD, Nazem Said).Start Printed Page 70268. documents in the last year, 25 PAINS VICTOIRE; a.k.a. [3] The Advisory illustrates its findings with a discussion of Nazem Said Ahmad, a Lebanon-based diamond dealer and art collector whom OFAC designated as a Specially Designated Global Terrorist, or SDGT, in December 2019 for his support of Hizballah. . The OFAC's Advisory followed its 2019 enforcement action against Nazem Ahmad, an art collector and gallery owner accused of evading US counterterrorism sanctions by using his multi-million . documents in the last year, 1059 AHMAD, Nazem Saeed; a.k.a. Source: Selections Arts Hizballah utilizes Ahmad and his companies to launder substantial amounts of money bound for the terrorist group. SAAB, Tony (a.k.a. Además de designar a Assi, OFAC está identificando el yate de Assi, el Dragón Volador, como propiedad bloqueada, en la que Assi tiene interés. On December 13, 2019, OFAC determined that the property and interests in property subject to U.S. jurisdiction of the following persons are blocked under the relevant sanctions authority listed below. The Office of Foreign Assets Control of the US Department of the Treasury has designated Nazem Said Ahmad, Saleh Assi, and Tony Saab pursuant to Executive Order 13224, as amended, for providing material assistance to Hizballah and sanctioned members of Hizballah. OFAC cites the example of Nazem Said Ahmad, a prominent Lebanon-based diamond dealer, art collector and Specially Designated Global Terrorist ("SDGT") with an alleged history of providing . This site uses cookies to enhance functionality and performance. 9. 2. MONTECARLO BEACH SAL, Beirut, Lebanon; Commercial Registry Number 44925 (Lebanon) [SDGT] (Linked To: AHMAD, Nazem Said). [11] As such, OFAC recommends that any U.S. person considering a transaction with a blocked person involving high-value artwork should seek legal advice or a license from OFAC.[12]. 09/21/2021, 841 In December 2019, OFAC designated Nazem Said Ahmed, a prominent Lebanon-based diamond dealer and art collector, pursuant to Executive Order (E.O.) But art businesses of all types and sizes will be wise to pay close attention to OFAC's pronouncement and to consider the recent advisory as an important warning shot. INTERALIMENT OFFSHORE COMPANY), Verdun 732 Center 3377/74 Mousseitbeh, Dar El-Fatwa Sector, Rachid Karame Sreet, Beirut, Lebanon; Verdun—Center, 730, Section 74 of the property 3377, Area Msaytbeh Real Estate—the fifth floor, Beirut, Lebanon; 732 Center, 5th Floor, Verdun Street, Beirut, Lebanon; D-U-N-S Number 557757412; Phone Number 9611797101; Registration ID 1239305; Commercial Registry Number 1801267 (Lebanon) [SDGT] (Linked To: ASSI, Saleh). Hughes Hubbard’s Art Law Group negotiates, litigates and advises clients on the full range of legal issues that arise concerning works of art, the art market and the art world. Abdul Majid since 2008 has served as a JAT leader, overseeing JAT fighters. AL DIBIYA 143 SAL), Adnane Al Hakim Street, Al-Wazeer Building, First Floor, Building No. 13. "Ahmad, who has a vast art collection, is one of Hezbollah's top . : 202-622-4855. OFAC's October 30, 2020 advisory further underscores OFAC's willingness to seek enforcement of sanctions violations against transactions arising from the art world. Lederman points to the 2019 sanctioning of Lebanese art collector, Nazem Said Ahmad, as a further example. 09/21/2021, 319 Federal Register issue. documents in the last year, by the National Oceanic and Atmospheric Administration It also provides an overview of situations in which sanctions violations—either inadvertent or purposeful—may arise. -- A stunning history of Lebanon over five centuries --"Skillfully weaving together social, political, cultural and economic history, this deeply informed and penetrating study provides a rich understanding of the vibrant, tragic, but ever ... 09/21/2021, 338 : 202-622-2420; Assistant Director for Sanctions Compliance & Evaluation, tel. to sanction and expose those involved in human rights abuses in Syria as well as senior Syrian government officials. She also has experience in antitrust matters. NOUMAYRIYE 1057 SAL (a.k.a. documents in the last year, 4 13224, as amended), for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of HIZBALLAH, a person whose property and interests in property are blocked pursuant to E.O. As a member of the art community, what are my compliance obligations with respect to Executive Order 13224, as amended?” (Dec. 13, 2019), available at https://home.treasury.gov/policy-issues/financial-sanctions/faqs/813. § 536.205(b) (including exemption for certain transactions involving "{i}nformation and informational materials" under the Narcotics Trafficking Sanctions Regulations). . In Cultural Property Crime, experts from a wide range of disciplines provide analytical insights into classical and contemporary criminal acts that affect our cultural heritage worldwide, both in peace and wartime. The following individuals have been added to OFAC's SDN List: AHMAD, Nazem Said (a.k.a. Afif Abdul Majid (Abdul Majid) is being designated for acting for or on behalf of JAT. Mohammed Shafi Armar, the fugitive chief recruiter for the ISIS in the Indian subcontinent, has been named a 'Specially Designated Global Terrorist' by the US on Thursday, becoming the first . The first named, Nazim Said Ahmad, was pictured in the Office of Foreign Assets Control (OFAC) press release in his Beirut penthouse, seated in front of a Jean-Michel Basquiat painting and sculpture by Robert Indiana. Patek has also trained operatives associated with the terrorist organization . Each document posted on the site includes a link to the OFAC Recent Actions. include documents scheduled for later issues, at the request AHMED, Nazem Said; a.k.a. 10. In 2012, Abdul Majid played a role in coordinating the activities of regional JAT leaders. In terms of what constitutes "high-value" art, OFAC urges "particular caution" when dealing with works with an estimated market value of more than $100,000. § 4305(b)(4).” Advisory at 3. American officials described the diamond dealer, Nazem Said Ahmad, who lives in Beirut, as … The advisory cites as an example the case of Nazem Said Ahmed, a diamond dealer and art collector designated in December 2019 pursuant to Executive Order 13224 for providing material support to Hizballah. A Lebanon-based diamond dealer and art collector, Nazem Said Ahmed, suspected of laundering substantial sums of money in support of Hizballah, a Specially Designated Global Terrorist group; Being added to OFAC's Specially Designated Nationals and Blocked Persons List means that U.S. citizens are forbidden to do business with Ahmad, and anyone who does…</p> You will also find expert assessment of the current inventory, plus future requirements, making Jane's World Air Forces an essential tool for threat assessment and market intelligence. . In 2019, OFAC designated Nazem Said Ahmed, a Lebanon-based diamond dealer and art collector, a Specially Designated Global Terrorist (SDGT). It makes recommendations for improving the collection and presentation of data and for greater clarity in communicating what the indicators can and cannot capture. In Portrayal and the Search for Identity, Marcia Pointon investigates how we view and understand portraiture as a genre and how portraits function as artworks within social and political networks. OFAC appears to have issued the Advisory in response to a bipartisan Senate Committee on Homeland Security and Governmental Affairs report (the “Senate Report”) issued on July 29, 2020 that identified the art market as both the “largest, legal, unregulated market in the United States” and a significant weakness in the nation’s sanctions and anti-money laundering regimes. 21 Washington also sanctioned his DRC-based associate and Hezbollah financier Saleh Assi, who "laundered money through Ahmad's diamond businesses," Treasury stated. Persons that have been added to ofac, Ahmad, Nazem Said ( a.k.a preview of documents scheduled for issues. The user to see how the document Drafting Handbook that agencies use to create their documents Register legal! 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