OFAC Designations Under CISADA: July 31, 2012

David Scantling filed this request with the Department of Treasury, Office of Foreign Asset Control of the United States of America.
Tracking # 2017- 07- 030
Due Aug. 2, 2017
Est. Completion None
Awaiting Response


From: David Scantling

Dear FOIA Officer:

1. This is a request under the Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, submitted to the Office of Foreign Assets Control ("OFAC") of the United States Department of the Treasury ("Treasury").

2. I hereby request agency records related to OFAC's July 31, 2012, designation of the following entities under the Comprehensive Iran Sanctions, Accountability, and Divestment Act ("CISADA"):

2.1. Bank of Kunlun Co. Ltd. (SWIFT Business Identifier Code: CKLBCNBJ); including the following locations:

2.1.1. 9 Dongzhimen North Street, Dongcheng District, Beijing 100007, China (head office);
2.1.2. No. 7 Century Ave, Karamay 834000 Xinjiang, China (registered office);
2.1.3. 172 Xibin Rd, Ranghulu District, Daqing 163453 (Heilongjiang branch); and,
2.1.4. No. 68 Zhongya South Rd, Economic and Technological Development Zone, Urumqi 830026 (Xinjiang branch).

2.2. Elaf Islamic Bank (SWIFT Business Identifier Code: ELAFIQBA); including the following location:

2.2.1. PO Box 3440, Bldg No. 14, Street 99, Hai Al Wehda-Mahala 902, Alweih, Baghdad, Iraq.

3. The following constraints limit this FOIA request:

3.1. Only the OFAC Designation/Evidentiary Package documents related to these entities are requested;
3.2. Excluding any documents containing the agency’s deliberative material or recommendations;
3.3. Excluding any documents classified Top Secret (“TS”), Sensitive Compartmented Information (“SCI”), and/or Special Access Program (“SAP”); however,
3.4. Including all of OFAC’s responsive documents that are classified below the TS, SCI and/or SAP levels; for example, any documents marked Unclassified (“U”), Sensitive But Unclassified (“SBU”), For Official Use Only (“FOUO”), Confidential (“C”), Law Enforcement Sensitive (“LES”), and/or Secret (“S”).

4. Although FOIA has always presumed that government records are open to public inspection, the FOIA Improvement Act of 2016, Pub. L. 114-185, prohibits agencies from withholding records unless (1) “disclosure is prohibited by law” or (2) “the agency reasonably foresees that disclosure would harm an interest protected by” one of FOIA’s exemptions. 5 U.S.C. § 552(a)(8)(A). Thus, in addition to FOIA favoring disclosure and requiring its exemptions to be narrowly construed, Section 552(a)(8)(A) prohibits agencies from using their discretion to broadly withhold records merely because they believe an exemption could technically apply.

5. In order to expedite OFAC’s release of the requested documents, please disclose them on an interim, rolling basis as they become available; for example, without waiting for all of the agency’s relevant systems of record to be searched, or all of its relevant records to be processed. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

6. If OFAC’s processing costs for this request exceed $350.00, please notify me in advance so that I might consider paying any additional fees for a complete and accurate set of responsive documents. The requested documents will be made available to the general public and this request is not being made for commercial purposes.

7. Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 20 business days, as the statute requires.


David Scantling


Good Afternoon Mr. Scantling,

Please see the Department of the Treasury's receipt letter pertaining to your recently submitted FOIA request. Please refer to the information provided in the receipt letter when inquiring about your FOIA request.

David Greek
U.S. Department of the Treasury
Government Information Specialist
Privacy, Transparency, and Records
Email: TreasFOIA@treasury.gov<mailto:TreasFOIA@treasury.gov>



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Good afternoon,

Your email has been sent to the Office of Foreign Assets Control for appropriate action. In the future, for FOIA requests addressed to OFAC, please reach out to them directly on the 202-622-2500.