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FEDERAL RESERVE BANK
OF NEW YORK
F is c a l A g e n t o f th e U n ite d S ta te s
Circular No.
[
10704 1
May 2 6 , 1994
INTERNATIONAL BANKING CONNECTIONS
OF THE GOVERNMENT OF LIBYA
To the Chief Operating Officers at All Financial Institutions,
and Others Concerned, in the Second Federal Reserve District:
P r i n t e d o n th e fo llo w in g p a g e s is a c h a r t , p r e p a r e d b y th e O f f ic e o f F o r e ig n A s s e ts C o n tr o l
( “ F A C ” ) o f th e U .S . D e p a r tm e n t o f th e T re a s u ry , s h o w in g th e r e la tio n s h ip o f t h e g o v e r n m e n t o f L ib y a
to 1 0 2 b a n k s a n d f in a n c ia l in s titu tio n s w o rld w id e . W e h a v e b e e n a d v is e d b y F A C th a t 2 3 o f th o s e
i n s t itu tio n s , a s w e ll a s 12 b a n k o f f ic e r s , a r e b lo c k e d u n d e r th e L ib y a n S a n c tio n s R e g u la tio n s . T h e
f in a l p a g e c o n ta in s a s ta te m e n t b y F A C d e s c r ib in g th e c h a r t ’s c o n te n ts a n d p u r p o s e .
I f y o u r i n s titu tio n h a s o v e r s e a s b r a n c h e s , p le a s e s e n d th e m a c o p y o f t h is n o tic e . A d d itio n a l
c o p ie s m a y b e o b ta in e d f r o m o u r C ir c u la r s D iv is io n (T e l. N o. 2 1 2 - 7 2 0 - 5 2 1 5 o r 5 2 1 6 ).
W il l ia m J . M c D o n o u g h ,
P resid en t.
This chart was released by the Office of Foreign Assets Control
("FAC") highlighting the Government of Libya's organizational
relationship to 102 banks and other financial entities worldwide.
The chart provides a detailed look at current Libyan shareholdings
and key Libyan officers in the complex web of financial
institutions in which Libya has become involved, some of which are
utilized by Libya to circumvent United Nations sanctions. It also
exposes the known scope of Libya's international banking network
and provides a visual reference for banks and businesses.
Of the 102 institutions depicted on the chart, 23 have been
determined by FAC to be "Specially Designated Nationals" ("SDNs")
of Libya. In addition, the chart lists 12 individual Libyan bank
officers who are Libyan SDNs.
Economic transactions with SDNs by U.S. persons anywhere in the
world are prohibited.
The 23 Libyan SDNs shown on the chart
include the Central Bank of Libya, the Libyan Arab Foreign Bank,
six other financial institutions in Libya, and 15 entities outside
of Libya determined by FAC to be owned or controlled by, or doing
business on behalf of, the Libyan Government.
In the U.S., doing business with entities owned or controlled by,
or doing business on behalf of the Libyan Government carries
criminal penalties of up to $500,000 per violation for corporations
and $250,000 per violation for individuals, plus prison sentences
of up to 10 years for individuals and participating corporate
officers. FAC also may levy administrative civil penalties of up
to $10,000 per violation.
The Libyan bank chart is intended to make U.S. persons aware of the
SDN status of the 23 Libyan Government-controlled institutions and
to ensure adherence with U.S. sanctions.
This is part of a
concerted United States and international effort to increase
economic pressure against Libya in response to Libya's continued
refusal to extradite the suspects of the Pan Am 103 bombing.
Recently, a number of actions have been taken internationally to
tighten sanctions against Libya, including the freezing of Libyan
accounts, the blocking of Libyan shares in commercial enterprises,
and the removal of key Libyan officers of major financial
institutions.
The chart on Libya's International Banking Connections may be
revised at any time, as new information becomes available to the
Treasury Department. Persons with information on entities with a
Libyan interest or individuals who act on behalf of Libya may call
202-622-2420. All calls will be kept confidential.
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@FedFRASER