FOLLOW-UP: BANK MELLI ATTEMPT TO PURCHASE A

S E C R E T LONDON 000196 SIPDIS NOFORN SIPDIS STATE FOR ISN, T, EUR, NEA TREASURY E.O. 12958: DECL: 01/22/2018 TAGS: KNNP MNUC EFIN ETTC SUBJECT: FOLLOW-UP: BANK MELLI ATTEMPT TO PURCHASE A TURKISH BANK TO CIRCUMVENT UNSCRS 1737 AND 1747 REF: SECSTATE 5584 Classified By: A/ECON MIN COUNSELOR SANDRA CLARK FOR REASONS 1.4 B & D ACTION REQUEST Paragraph 2 ¶1. (S/NF) HM Treasury appreciates the information contained in reftel and promised to look into evidence of any Bank Melli activity in London and possible measures the UK could take to disrupt the Turkish transaction, according to Patrick Guthrie, Head of Financial Sanctions Unit, HMT. However, Guthrie said HMT lawyers did not believe that Bank Melli's relationship with Bank Sepah rose to the status of "agency" or "acting on behalf of" that would trigger automatic sanctions per UNSCRs 1737 and 1747. Guthrie promised HMT would look further into the resolutions' language and compare it to UK legal interpretations of those relationships. ¶2. (S/NF) ACTION REQUEST: We would appreciate a legal analysis of UNSCRs 1737 and 1747, specifically defining the terms "agency", "acting on behalf of", "providing financial support", and "facilitating transactions", which we can share with UK lawyers. Visit London's Classified Website: http://www.state.sgov.gov/p/eur/london/index. cfm Tuttle