VZCZCXYZ0010
OO RUEHWEB

DE RUEHC #9967 3301538
ZNR UUUUU ZZH
O 261527Z NOV 07
FM SECSTATE WASHDC
TO RUEHSM/AMEMBASSY STOCKHOLM IMMEDIATE 0000
RUCNDT/USMISSION USUN NEW YORK IMMEDIATE 0000

UNCLAS STATE 159967 
 
SIPDIS 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: KNNP IR PREL PARM
SUBJECT: USG QUESTIONS ON SWEDEN NOVEMBER 9 NOTICE ON BANK 
SEPAH 
 
REF: A. A) NOTE VERBALE 
 
     ¶B. 9 NOVEMBER 2007 
 
¶1.  (U)  This is an action request.  Please see paragraph 3. 
 
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SUMMARY 
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¶2.  (U)  On 9 November, Sweden notified the UNSCR 1737 
Sanctions Committee of its intention to authorize-under 
paragraph 15 of UNSCR 1737-payments due under contracts with 
Bank Sepah entered into prior to the listing of Bank Sepah in 
Annex I of UNSCR 1747.  Washington would like to request that 
Sweden provide more information to the Committee and the U.S. 
regarding these payments and the underlying contracts in 
order to confirm that the authorization of such payments is 
fully consistent with the terms of paragraph 15 of UNSCR 1737 
and with recent Financial Action Task Force guidance on 
financial sanctions against a financial institution 
designated under UNSCRs related to WMD proliferation. 
 
 
¶3.  (U)  In accordance with paragraph 15 of UNSCR 1737 and 
paragraph 4 of 1747, Sweden may authorize these payments as 
early as November 23.  We wish to immediately convey our 
request to the GOS, prior to the payment of any funds, and 
ask the GOS to delay authorization or withdraw its 
notification until more information is provided on the 
contracts and the nature of the transactions for which the 
unfrozen funds will be used. 
 
¶4.  (U)  FATF guidance regarding Bank Sepah can be found at 
the following web address: 
http://www.fatf-gafi.org/dataoecd/23/16/39318 680.pdf 
 
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OBJECTIVES 
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¶5.  (U)  Washington requests Mission approach appropriate 
Swedish government officials to discuss this issue drawing 
from paragraphs 2 and 3 and the objectives outlined below. 
 
--  To ensure that the payments and underlying contracts 
referenced in Sweden's November 9 Note Verbale meet the terms 
of paragraph 15 of UNSCR 1737; in particular that the 
contracts were entered into before Bank Sepah's listing and 
do not relate to dual-use materials that could be captured 
under paragraphs 3 or 4 of that resolution. 
 
--  To ask for additional details - prior to the payment of 
any funds - about: 
 
----  The payments that will be made under this notification, 
such as the payment beneficiaries, the type of contract 
involved, the dates the contracts were entered into, the date 
or dates of legal obligations to pay, and the amount of money 
(and type of currency) that is owed; 
 
----- Whether these payments will be made under discretionary 
facilities, such as overdrafts or revolving facilities, that 
could constitute new banking business with  Bank Sepah and 
would be inconsistent with recent guidance from FATF; 
 
----  The services that have been or will be rendered under 
the prior contracts, and when payment is due for those 
services; 
 
----  The types of goods involved and if these prior 
contracts involve the shipment of goods to Iran; and 
 
----  The source of the funds that will be used to pay these 
prior contracts, and whether funds will be transferred into a 
Swedish account of Bank Sepah, and if so, at which bank. 
 
---- The safeguards Sweden has in place, consistent with 
recent FATF guidance, to ensure that only permitted payments 
are made and to prevent new banking business with Bank Sepah. 
 
 
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REPORTING DEADLINE 
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¶6.  (U)  Mission should report results by November 30. 
Please slug replies for ISN, IO, T, TREASURY, EUR and NEA. 
Please include SIPDIS in all replies. 
 
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POINT OF CONTACT 
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¶7.   (U) Washington point of contact for follow-up 
information is Kevin McGeehan, ISN/CPI, (202) 647-5408, 
McGeehanKJ@state.sgov.gov and John Sandage, IO/PSC, (202- 
736-7739, SandageJB@state.gov. 
 
¶8. (U) Department thanks Posts for its assistance. 
RICE