Case No. GLOMAG-2019-363474-1
CALIDUS LLC
AL BUSTAN OFFICE TOWER, UNIT 304
AIRPORT ROAD AND RABDAN ST
ABU DHABI, ABU DHABI 6601
UNITED ARAB EMIRATES
Attn:
[email protected]
Dear Sir or Madam:
This letter responds to your request of October 7, 2019, to the Office of Foreign Assets Control (OFAC) requesting a reconsideration of OFAC's decision not to license the release of the following blocked funds transfer:
Originator: Calidus LLC
Originating Bank: First Abu Dhabi Bank P.J.S.C
Value Date: 10/16/2018
Amount: $582,000.00
Beneficiary Bank: Komercijalna Banka a.d. Beograd
Beneficiary: Falcon Strategic Solutions DOO
OFAC licenses the release of blocked funds only under limited and compelling circumstances consistent with the national security and foreign policy interests of the United States. OFAC has reviewed the information...
1) Case No. GLOMAG-2019-363474-1 arises from a wire, initiated on 10/16/2018, to a beneficiary (Falcon Strategic Solutions D.O.O.) that was not added to the SDN list until 9/12/2019. The beneficiary, however, "was established by [an SDN individual] immediately following his December 21, 2017 designation to avoid sanctions" (https://home.treasury.gov/news/press-releases/sm849).
According to the government in a forfeiture complaint aimed at forfeiting the funds blocked, "Partizan Tech DOO (“Partizan Tech”), Tehnoglobal Systems DOO Beograd (“Tehnoglobal”), and Grawit Limited [all SDNs]...used a series of front companies, including Falcon, Finrost, and Vectura, to continue conducting correspondent banking transactions through the U.S. financial system, in violation of the International Emergency Economic Powers Act..." (See p. 3, PDF). "[Falcon Strategic Solutions D.O.O.] was established on or about December 29, 2017, and was utilized to receive payments on behalf of Partizan...