As I blogged here literally less than 10 minutes ago…

The EU added the following persons:

1. AL-BARAZI, Talal

DOB: –/–/1963. POB: Hama city, Syria a.k.a: BARAZI, Talal Position: Minister of Internal Trade and Consumer Protection. Appointed in May 2020. Other Information: Gender: male. Listed on: 16/10/2020 Last Updated: 16/10/2020 Group ID: 13976.

2. KHAZIM, Zuhair

DOB: –/–/1963. POB: (1) Ain al-Tinah (2) Lattakia, (1) Syria (2) Syria a.k.a: KHAZIM, Zouhair Position: Minister of Transport. Appointed in August 2020. Other Information: Gender: male. Listed on: 16/10/2020 Last Updated: 16/10/2020 Group ID: 13982.

3. MOUCHAWEH, Loubana

DOB: –/–/1955. POB: Damascus, Syria a.k.a: (1) MOUCHAWEH, Lubana (2) MSHAWEH, Loubana (3) MSHAWEH, Lubana Position: Culture Minister. Appointed in August 2020. Other Information: Gender: female. Listed on: 16/10/2020 Last Updated: 16/10/2020 Group ID: 13977.

4. RA’AD, Tammam

DOB: –/–/1965. POB: (1) Al-Qusayr (2) Homs, (1) Syria (2) Syria a.k.a: (1) RAAD, Tamam (2) RA’AD, Tamam (3) RAAD, Tammam Position: Minister of Hydraulic/Water Resources. Appointed in August 2020. Other Information: Gender: male. Listed on: 16/10/2020 Last Updated: 16/10/2020 Group ID: 13980.

5. SAYYED, Ahmad

DOB: –/–/1965. POB: Quneitra, Syria a.k.a: (1) AL-SAYED, Ahmad (2) AL-SAYYED, Ahmad (3) ALSYED, Ahmad Position: Minister of Justice. Appointed in August 2020. Other Information: Gender: male. Listed on: 16/10/2020 Last Updated: 16/10/2020 Group ID: 13979.

6. TABA’A, Darem

DOB: –/–/1958. POB: Damascus, Syria Position: Minister of Education. Appointed in August 2020. Other Information: Gender: male. Listed on: 16/10/2020 Last Updated: 16/10/2020 Group ID: 13978.

7. YAGHI, Kinan

DOB: –/–/1976. POB: Salmiya, Hama countryside, Syria a.k.a: (1) YAGHI, Kenan (2) YAGI, Kenan (3) YAGI, Kinan Position: Minister of Finance. Appointed in August 2020. Other Information: Gender: male. Listed on: 16/10/2020 Last Updated: 16/10/2020 Group ID: 13981.

to their Syria sanctions list under Council Implementing Regulation (EU) 2020/1505… and now the UK has added them, too.

The EU’s press release didn’t say this, but the regulation also implemented 18 updates:

1. AYYUB, Ali Abdullah

DOB: –/–/1952. POB: Lattakia, Syria a.k.a: (1) AYOB, Ali, Abdallah (2) AYOB, Ali, Abdullah (3) AYOUB, Ali, Abdallah (4) AYOUB, Ali, Abdullah (5) AYUB, Ali , Abdullah (6) AYUB, Ali, Abdallah (7) AYYOUB, Ali, Abdullah (8) AYYOUB, Ali, Abdallah (9) AYYUB, Ali, Abdallah Position: (1) Vice President of the Council of Ministers (2) Minister of Defence. Appointed in January 2018. Other Information: Gender: male. Officer of the rank of General in the Syrian Army. Former Chief of General Staff of the Syrian Armed Forces. Listed on: 15/11/2011 Last Updated: 04/06/2020 16/10/2020 Group ID: 12211.

2. KHAMIS, Imad Mohammad Deeb

DOB: 01/08/1961. POB: near Damascus, Syria a.k.a: (1) KHAMEES, Imad, Mohammad, Dib (2) KHAMIS, Imad, Mohamed, Deeb (3) KHAMIS, Imad, Mohammed, Deeb (4) KHAMIS, Imad, Muhammad, Deeb Position: Prime Minister Other Information: Gender: male. Former Prime Minister. Former Minister of Electricity Listed on: 26/03/2012 Last Updated: 04/06/2020 16/10/2020 Group ID: 12636.

3. YAZAJI, Nizar Wahbeh

DOB: –/–/1961. POB: Damascus, Syria a.k.a: YAZIGI, Nizar, Wehbe Position: Minister of Health since August 2014 Other Information: Gender: male. Former Minister of Health. Listed on: 22/10/2014 Last Updated: 04/06/2020 16/10/2020 Group ID: 13156.

4. AL-QADRI, Ahmad

DOB: –/–/1956. Position: Agriculture and Agrarian Reform Minister Other Information: Gender: male. Former Agriculture and Agrarian Reform Minister. Listed on: 24/06/2014 Last Updated: 04/06/2020 16/10/2020 Group ID: 12986.

5. ARNOUS, Hussein

DOB: –/–/1953. a.k.a: ARNUS, Hussein Position: Water Resources Minister Prime Minister. Appointed in August 2020. Other Information: Gender: male. Listed on: 24/06/2014 Last Updated: 04/06/2020 16/10/2020 Group ID: 12996.

6. NADDAF, Atef

DOB: –/–/1956. POB: Damascus countryside, Syria Position: Minister of Internal Trade and Consumer Protection. Appointed in November 2018. Other Information: Gender: male. Former Minister of Internal Trade and Consumer Protection. Listed on: 14/11/2016 Last Updated: 04/06/2020 16/10/2020 Group ID: 13396.

7. MAKHLOUF, Hussein

DOB: –/–/1964. POB: Lattakia, Syria a.k.a: MAKHLUF, Hussein Position: Local Administration Minister Appointed in July 2016 Minister of Local Administration and Environment Other Information: Gender: male. Former Governor of Damascus Governorate. Cousin of Rami Makhlouf. Listed on: 14/11/2016 Last Updated: 04/06/2020 16/10/2020 Group ID: 13397.

8. GHANEM, Ali

DOB: –/–/1963. POB: Damascus, Syria Position: Minister for Petroleum and Mineral Resources. Appointed in July 2016. Other Information: Gender: male. Former Minister for Petroleum and Mineral Resources. Listed on: 14/11/2016 Last Updated: 04/06/2020 16/10/2020 Group ID: 13399.

9. AL-AHMED, Mohammed

DOB: –/–/1961. POB: Lattakia, Syria a.k.a: (1) AL-AHMAD, Mohamed (2) AL-AHMAD, Mohammad (3) AL-AHMAD, Mohammed (4) AL-AHMAD, Muhammad (5) AL-AHMED, Mohamed (6) AL-AHMED, Mohammad (7) AL-AHMED, Muhammad Position: Culture Minister. Appointed in July 2016. Other Information: Gender: male. Former Culture Minister. Listed on: 14/11/2016 Last Updated: 04/06/2020 16/10/2020 Group ID: 13401.

10. HAMOUD, Ali

DOB: –/–/1964. POB: Tartus, Syria a.k.a: HAMMOUD, Ali Position: Transport Minister. Appointed in July 2016. Other Information: Gender: male. Former Transport Minister. Listed on: 14/11/2016 Last Updated: 04/06/2020 16/10/2020 Group ID: 13402.

11. KHARBOUTLI, Mohammed Zuhair

POB: Damascus, Syria a.k.a: KHARBOUTLI, Mohammed, Zahir Position: Electricity Minister. Appointed in July 2016. Other Information: Gender: male. Former Electricity Minister. Listed on: 14/11/2016 Last Updated: 04/06/2020 16/10/2020 Group ID: 13403.

12. HAMDAN, Maamoun

DOB: –/–/1958. POB: Damascus, Syria a.k.a: HAMDAN, Ma’moun Position: Finance Minister. Appointed in July 2016. Other Information: Gender: male. Former Finance Minister. Listed on: 14/11/2016 Last Updated: 04/06/2020 16/10/2020 Group ID: 13404.

13. ABDULLAH, Abdullah

DOB: –/–/1956. Position: State Minister. Appointed in July 2016. Other Information: Gender: male. Former State Minister. Listed on: 14/11/2016 Last Updated: 04/06/2020 16/10/2020 Group ID: 13408.

14. ABDULLAH, Salwa

DOB: –/–/1953. POB: Quneitra, Syria Position: State Minister. Appointed in July 2016. Minister of Social Affairs and Labour. Appointed in August 2020 Other Information: Gender: female. Former State Minister. Listed on: 14/11/2016 Last Updated: 04/06/2020 16/10/2020 Group ID: 13409.

15. SA’AD, Rafe’a Abu

DOB: –/–/1954. POB: Habran Village, Sweida province, Syria a.k.a: SAAD, Rafe’a Abu Position: State Minister. Appointed in July 2016. Other Information: Gender: male. Former State Minister. Listed on: 14/11/2016 Last Updated: 04/06/2020 16/10/2020 Group ID: 13410.

16. AL-SHA’AR, Hisham Mohammad Mamdouh

DOB: –/–/1958. POB: Damascus, Syria Position: Justice Minister. Appointed in March 2017. Other Information: Gender: male. Former Justice Minister. Listed on: 07/06/2017 Last Updated: 04/06/2020 16/10/2020 Group ID: 13468.

17. AL-AZAB, Imad Muwaffaq

DOB: –/–/1970. POB: Damascus countryside, Syria Position: Minister of Education. Appointed in November 2018. Other Information: Gender: male. Former Minister of Education. Listed on: 04/03/2019 Last Updated04/06/2020 16/10/2020 Group ID: 13773.

18. AL-ABIDIN JAZBA, Mohammad Maen Zein-Al-Abidin Jazba

DOB: –/–/1962. POB: Aleppo, Syria Position: Minister of Industry. Appointed in November 2018 Other Information: Gender: male. Former Minister of Industry. Listed on: 04/03/2019 Last Updated: 04/06/2020 16/10/2020 Group ID: 13777.

Links:

OFSI Notice

Council Implementing Regulation (EU) 2020/1505

Earlier today (sorry!), OFAC added the following entities:

BAYAN RASANEH GOSTAR INSTITUTE (a.k.a. BAYAN GOSTAR MEDIA INSTITUTE; a.k.a. BAYAN RASANE GOSTAR INSTITUTE), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [ELECTION-EO13848] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE). 
 
INTERNATIONAL UNION OF VIRTUAL MEDIA (a.k.a. IUVM), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [ELECTION-EO13848] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE). 
 
ISLAMIC RADIO AND TELEVISION UNION (a.k.a. IRTVU), Iran; Beirut, Lebanon; Kabul, Afghanistan; Additional Sanctions Information – Subject to Secondary Sanctions [ELECTION-EO13848] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE). 

to its Foreign Interference in U.S. Election sanctions program.

They also added the following persons:

AL-BAGHDADI, Hassan (Arabic: حسن بغدادي) (a.k.a. AL-BAGHDADI, Sheikh Hassan; a.k.a. BAGHDADI, Sheikh Hassan; a.k.a. “AL-BAGHDADI, Sheikh”), Lebanon; DOB 05 Oct 1961; citizen Lebanon; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Gender Male (individual) [SDGT] (Linked To: HIZBALLAH). 
 
MASJEDI, Iraj, Iraq; DOB 1957; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE). 
 
QAOUK, Nabil (Arabic: نبيل قاووق) (a.k.a. KAWOUK, Nabil; a.k.a. QAWOOK, Sheikh Nabil; a.k.a. QAWOUK, Sheikh Nabil; a.k.a. QAWUQ, Nabil Yahy), Ebba, Nabatieh, Lebanon; DOB 20 May 1964; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Gender Male (individual) [SDGT] (Linked To: HIZBALLAH). 

to its global counter-terrorism sanctions program (Masjedi was also added to the IFSR and IRGC Iran sanctions program).

Also, the following entity listings:

ISLAMIC REVOLUTIONARY GUARD CORPS (a.k.a. AGIR; a.k.a. ARMY OF THE GUARDIANS OF THE ISLAMIC REVOLUTION; a.k.a. IRAN’S REVOLUTIONARY GUARD CORPS; a.k.a. IRAN’S REVOLUTIONARY GUARDS; a.k.a. IRG; a.k.a. IRGC; a.k.a. ISLAMIC REVOLUTION GUARDS CORPS; a.k.a. ISLAMIC REVOLUTIONARY CORPS; a.k.a. ISLAMIC REVOLUTIONARY GUARDS; a.k.a. ISLAMIC REVOLUTIONARY GUARDS CORPS; a.k.a. PASDARAN; a.k.a. PASDARAN-E INQILAB; a.k.a. PASDARN-E ENGHELAB-E ISLAMI; a.k.a. REVOLUTIONARY GUARD; a.k.a. REVOLUTIONARY GUARDS; a.k.a. SEPAH; a.k.a. SEPAH PASDARAN; a.k.a. SEPAH-E PASDARAN ENGHELAB ISLAMI; a.k.a. SEPAH-E PASDARAN-E ENGHELAB-E ESLAMI; a.k.a. SEPAH-E PASDARAN-E ENQELAB-E ESLAMI; a.k.a. THE ARMY OF THE GUARDIANS OF THE ISLAMIC REVOLUTION; a.k.a. THE IRANIAN REVOLUTIONARY GUARDS), Tehran, Iran; Syria; Additional Sanctions Information – Subject to Secondary Sanctions [FTO] [SDGT] [NPWMD] [IRGC] [IFSR] [IRAN-HR] [HRIT-IR]. -to- ISLAMIC REVOLUTIONARY GUARD CORPS (a.k.a. AGIR; a.k.a. ARMY OF THE GUARDIANS OF THE ISLAMIC REVOLUTION; a.k.a. IRAN’S REVOLUTIONARY GUARD CORPS; a.k.a. IRAN’S REVOLUTIONARY GUARDS; a.k.a. IRG; a.k.a. IRGC; a.k.a. ISLAMIC REVOLUTION GUARDS CORPS; a.k.a. ISLAMIC REVOLUTIONARY CORPS; a.k.a. ISLAMIC REVOLUTIONARY GUARDS; a.k.a. ISLAMIC REVOLUTIONARY GUARDS CORPS; a.k.a. PASDARAN; a.k.a. PASDARAN-E INQILAB; a.k.a. PASDARN-E ENGHELAB-E ISLAMI; a.k.a. REVOLUTIONARY GUARD; a.k.a. REVOLUTIONARY GUARDS; a.k.a. SEPAH; a.k.a. SEPAH PASDARAN; a.k.a. SEPAH-E PASDARAN ENGHELAB ISLAMI; a.k.a. SEPAH-E PASDARAN-E ENGHELAB-E ESLAMI; a.k.a. SEPAH-E PASDARAN-E ENQELAB-E ESLAMI; a.k.a. THE ARMY OF THE GUARDIANS OF THE ISLAMIC REVOLUTION; a.k.a. THE IRANIAN REVOLUTIONARY GUARDS), Tehran, Iran; Syria; Additional Sanctions Information – Subject to Secondary Sanctions [FTO] [SDGT] [NPWMD] [IRGC] [IFSR] [IRAN-HR] [HRIT-IR] [ELECTION-EO13848]. 
 
ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE (a.k.a. AL QODS; a.k.a. IRGC-QF; a.k.a. IRGC-QUDS FORCE; a.k.a. ISLAMIC REVOLUTIONARY GUARD CORPS-QODS FORCE; a.k.a. JERUSALEM FORCE; a.k.a. PASDARAN-E ENGHELAB-E ISLAMI (PASDARAN); a.k.a. QODS (JERUSALEM) FORCE OF THE IRGC; a.k.a. QODS FORCE; a.k.a. QUDS FORCE; a.k.a. SEPAH-E QODS; a.k.a. SEPAH-E QODS (JERUSALEM FORCE)), Tehran, Iran; Syria; Additional Sanctions Information – Subject to Secondary Sanctions [FTO] [SDGT] [SYRIA] [IRGC] [IFSR] [IRAN-HR]. -to- ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE (a.k.a. AL QODS; a.k.a. IRGC-QF; a.k.a. IRGC-QUDS FORCE; a.k.a. ISLAMIC REVOLUTIONARY GUARD CORPS-QODS FORCE; a.k.a. JERUSALEM FORCE; a.k.a. PASDARAN-E ENGHELAB-E ISLAMI (PASDARAN); a.k.a. QODS (JERUSALEM) FORCE OF THE IRGC; a.k.a. QODS FORCE; a.k.a. QUDS FORCE; a.k.a. SEPAH-E QODS; a.k.a. SEPAH-E QODS (JERUSALEM FORCE)), Tehran, Iran; Syria; Additional Sanctions Information – Subject to Secondary Sanctions [FTO] [SDGT] [SYRIA] [IRGC] [IFSR] [IRAN-HR] [ELECTION-EO13848]. 

were updated. They’re all under the Foreign Terrorist Organizations (FTO) program, the global terrorism program (SDGT), the election interference program, the Islamic Revolutionary Guard Corps (IRGC) program, the Iranian Financial Sanctions Regulations (IFSR) program, the Iran human rights program (IRAN-HR)…. Among others…

And the State Department issued two press releases – one for Iraj Masjedi:

United States Designates Senior Iranian Official in Iraq

PRESS STATEMENT

MICHAEL R. POMPEO, SECRETARY OF STATE

OCTOBER 22, 2020

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And one for the Hizaballah-affiliated individuals:

United States Sanctions Two Hizballah Officials

PRESS STATEMENT

MICHAEL R. POMPEO, SECRETARY OF STATE

OCTOBER 22, 2020

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Similarly, Treasury issued two press releases – this one:

and this one:

Links:

OFAC Notice

State Department Press Releases – Iraj Masjedi, Hizballah

Treasury Department Press Releases – Iraj Masjedi, Hizballah

Swiss authorities added the following persons:

SSID: 200-43776 Name: Talal Al-Barazi

Sex: M DOB: 1963 POB: Hama, Syrian Arab Republic Good quality a.k.a.: Barazi Justification: Minister of Internal Trade and Consumer Protection. Appointed in May 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 30 Oct 2020

SSID: 200-43783 Name: Loubana Mouchaweh

Sex: W DOB: 1955 POB: Damascus, Syrian Arab Republic Good quality a.k.a.: a) Lubana b) Mshaweh

Justification: Culture Minister. Appointed in Aug 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 30 Oct 2020

SSID: 200-43791 Name: Darem Taba’a

Sex: M DOB: 1958 POB: Damascus, Syrian Arab Republic

Justification: Minister of Education. Appointed in Aug 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 30 Oct 2020

SSID: 200-43797 Name: Ahmad Sayyed

Sex: M DOB: 1965 POB: Quneitra, Syrian Arab Republic Good quality a.k.a.: Alsyed (al- Sayyed, al-Sayed)

Justification: Minister of Justice. Appointed in Aug 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 30 Oct 2020

SSID: 200-43804 Name: Tammam Ra’ad

Sex: M DOB: 1965 POB: a) Al-Qusayr, Syrian Arab Republic b) Homs, Syrian Arab Republic Good quality a.k.a.: a) Tamam b) Raad

Justification: Minister of Hydraulic/Water Resources. Appointed in Aug 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 30 Oct 2020

SSID: 200-43814 Name: Kinan Yaghi

Sex: M DOB: 1976 POB: Salmiya, Hama countryside, Syrian Arab Republic Good quality a.k.a.: a) Kenan b) Yagi

Justification: Minister of Finance. Appointed in Aug 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 30 Oct 2020

SSID: 200-43825 Name: Zuhair Khazim

Sex: M DOB: 1963 POB: a) Ain al-Tinah, Syrian Arab Republic b) Lattakia, Syrian Arab Republic Good quality a.k.a.: Zouhair

Justification: Minister of Transport. Appointed in Aug 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 30 Oct 2020

and amended the following individual designations:

SSID: 200-11951 Name: Ali Abdullah Ayyub

Sex: M DOB: 1952 POB: Lattakia, Syrian Arab Republic Good quality a.k.a.: a) Abdallah b) Ayyoub (Ayub, Ayoub, Ayob)

Justification: Vice President of the Council of Ministers and Minister of Defence. Appointed in Jan 2018. Officer of the rank of General in the Syrian Army, in post after May 2011. Former Chief of General Staff of the Syrian Armed Forces. Person supporting the Syrian regime and responsible for repression of and violence against the civilian population in Syria. Modifications: Amended on 6 Nov 2013, 19 Jan 2016, 11 Oct 2016, 7 Mar 2018, 26 Jun 2020, 30 Oct 2020

SSID: 200-12259 Name: Imad Mohammad Deeb Khamis

Sex: M DOB: 1 Aug 1961 POB: near Damascus, Syrian Arab Republic Good quality a.k.a.: a) Muhammad (Mohamed, Mohammed) b) Dib c) Khamees

Justification: Former Prime Minister and formerFormer Minister of Electricity. As a former Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Amended on 6 Nov 2013, 19 Jan 2016, 16 Jun 2017, 12 Jun 2018, 26 Jun 2020, 30 Oct 2020

SSID: 200-28004 Name: Ahmad al-Qadri

Sex: M DOB: 1956

Justification: Former Agriculture and Agrarian Reform Minister. As a former Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 5 Aug 2014, amended on 26 Jun 2020, 30 Oct 2020

SSID: 200-28055 Name: Hussein Arnous

Sex: M DOB: 1953 POB: Idleb, Syrian Arab Republic Good quality a.k.a.: Arnus Justification: Water ResourcesPrime Minister. Appointed in Aug 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 5 Aug 2014, amended on 17 Jul 2019, 26 Jun 2020, 30 Oct 2020

SSID: 200-29860 Name: Nizar Wahbeh Yazaji

Sex: M DOB: 1961 POB: Damascus, Syrian Arab Republic Good quality a.k.a.: a) Wehbe b) Yazigi

Justification: Former Minister of Health since 27.8.2014Health. As a former Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 17 Dec 2014, amended on 26 Jun 2020, 30 Oct 2020

SSID: 200-35622 Name: Atef Naddaf

Sex: M DOB: 1956 POB: Damascus Countryside, Syrian Arab Republic

Justification: Former Minister of Internal Trade and Consumer Protection. Appointed in Nov 2018. As a former Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 9 Dec 2016, amended on 16 Jun 2017, 17 Jul 2019, 13 Aug 2019, 26 Jun 2020, 30 Oct 2020

SSID: 200-35628 Name: Hussein Makhlouf

Sex: M DOB: 1964 POB: Lattakia, Syrian Arab Republic Good quality a.k.a.: Makhluf Justification: LocalMinister of local Administration Minister. Appointed in Jul 2016and environment. Former Governor of Damascus Governorate. As a Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Cousin of Rami Makhlouf. Relation: Cousin of Rami Makhlouf (SSID 200-11672) Modifications: Listed on 9 Dec 2016, amended on 16 Jun 2017, 13 Aug 2019, 26 Jun 2020, 30 Oct 2020

SSID: 200-35647 Name: Ali Ghanem

Sex: M DOB: 1963 POB: Damascus, Syrian Arab Republic

Justification: Former Minister for Petroleum and Mineral Resources. Appointed in Jul 2016. As a former Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 9 Dec 2016, amended on 16 Jun 2017, 13 Aug 2019, 26 Jun 2020, 30 Oct 2020

SSID: 200-35663 Name: Mohammed al-Ahmed

Sex: M DOB: 1961 POB: Lattakia, Syrian Arab Republic Good quality a.k.a.: a) al-Ahmad b) Mohamed (Muhammad, Mohammad)

Justification: Former Culture Minister. Appointed in Jul 2016. As a former Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 9 Dec 2016, amended on 13 Aug 2019, 26 Jun 2020, 30 Oct 2020

SSID: 200-35672 Name: Ali Hamoud

Sex: M DOB: 1964 POB: Tartus, Syrian Arab Republic Good quality a.k.a.: Hammoud Justification: Former Transport Minister. Appointed in Jul 2016. As a former Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 9 Dec 2016, amended on 16 Jun 2017, 13 Aug 2019, 26 Jun 2020, 30 Oct 2020

SSID: 200-35680 Name: Mohammed Zuhair Kharboutli

Sex: M POB: Damascus, Syrian Arab Republic Good quality a.k.a.: Zahir

Justification: Former Electricity Minister. Appointed in Jul 2016. As a former Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 9 Dec 2016, amended on 16 Jun 2017, 13 Aug 2019, 26 Jun 2020, 30 Oct 2020

SSID: 200-35688 Name: Maamoun Hamdan

Sex: M DOB: 1958 POB: Damascus, Syrian Arab Republic Good quality a.k.a.: Ma’moun Justification: Former Finance Minister. Appointed in Jul 2016. As a former Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 9 Dec 2016, amended on 16 Jun 2017, 13 Aug 2019, 26 Jun 2020, 30 Oct 2020

SSID: 200-35718 Name: Abdullah Abdullah

Sex: M DOB: 1956

Justification: Former State Minister. Appointed in Jul 2016. As a former Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 9 Dec 2016, amended on 16 Jun 2017, 13 Aug 2019, 26 Jun 2020, 30 Oct 2020

SSID: 200-35724 Name: Salwa Abdullah

Sex: W DOB: 1953 POB: Quneitra, Syrian Arab Republic

Justification: Minister of social affairs and labour. Appointed in Aug 2020. Former State Minister. Appointed in Jul 2016. As a Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 9 Dec 2016, amended on 16 Jun 2017, 13 Aug 2019, 26 Jun 2020, 30 Oct 2020

SSID: 200-35731 Name: Rafe’a Abu Sa’ad

Sex: M DOB: 1954 POB: Habran Village, Sweida Province, Syrian Arab Republic Good quality a.k.a.: Saad

Justification: Former State Minister. Appointed in Jul 2016. As a former Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 9 Dec 2016, amended on 16 Jun 2017, 13 Aug 2019, 26 Jun 2020, 30 Oct 2020

SSID: 200-36364 Name: Hisham Mohammad Mamdouh Al-Sha’ar

Sex: M DOB: 1958 POB: Damascus, Syrian Arab Republic

Justification: Former Justice Minister. Appointed in Mar 2017As a former Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 16 Jun 2017, amended on 26 Jun 2020, 30 Oct 2020

SSID: 200-40333 Name: Imad Muwaffaq al-Azab

Sex: M DOB: 1970 POB: Damascus Countryside, Syrian Arab Republic

Justification: Former Minister of Education. Appointed in Nov 2018. As a former Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 17 Jul 2019, amended on 13 Aug 2019, 26 Jun 2020, 30 Oct 2020

SSID: 200-40359 Name: Mohammad Maen Zein-al-Abidin JazbaZein Jazba Al-Abidin

Sex: M DOB: 1962 POB: Aleppo, Syrian Arab Republic

Justification: Former Minister of Industry. Appointed in Nov 2018. As a former Government Minister, shares responsibility for the Syrian regime’s violent repression of the civilian population. Modifications: Listed on 17 Jul 2019, amended on 13 Aug 2019, 26 Jun 2020, 30 Oct 2020

under their Syrian sanctions program (purely a travel sanctions program).

Links:

FINMA Notice

Data files of updates – PDF, XML

Link:

EU Notice

Pursuant to Council Implementing Regulation (EU) 2020/1649, UK regulators added the following persons to their Syria sanctions program:

1. TOU’MA, Bassam

DOB: –/–/1969. POB: Safita, Syria a.k.a: TU’MA, Bassam Position: Minister of Oil and Mineral Resources. Appointed in August 2020. Other Information: Gender: male. Listed on: 06/11/2020 Last Updated: 06/11/2020 Group ID: 13997.

2. GHABACHE, Hassan

DOB: –/–/1971. POB: Damascus, Syria a.k.a: (1) AL-GHABBASH, Hassan (2) GHOBASH, Hassan Position: Minister of Health. Appointed in August 2020. Other Information: Gender: male. Listed on: 06/11/2020 Last Updated: 06/11/2020 Group ID: 13998.

3. SABBAGH, Ziyad

DOB: –/–/1960. POB: Aleppo, Syria Position: Minister of Industry. Appointed in August 2020 Other Information: Gender: male. Listed on: 06/11/2020 Last Updated: 06/11/2020 Group ID: 13999.

4. QATANA, Mohammad Hassan

POB: Damascus, Syria Position: Minister of Agriculture and Agrarian Reform. Appointed in August 2020 Other Information: Gender: male. Listed on: 06/11/2020 Last Updated: 06/11/2020 Group ID: 14000.

5. ZAMEL, Ghassan

DOB: –/–/1963. POB: Damascus, Syria a.k.a: (1) AL-ZAMEL, Ghassan (2) AL-ZAMIL, Ghassan Position: Minister of Electricity. Appointed in August 2020. Other Information: Gender: male. Listed on: 06/11/2020 Last Updated: 06/11/2020 Group ID: 14001.

6. BARCHA, Mohamad Fayez

DOB: –/–/1955. POB: Damascus, Syria a.k.a: (1) AL-BARASHA, Mohamad, Fayez (2) AL- BARASHA, Mohammad, Fayez (3) AL-BARSHA, Mohamad, Fayez (4) AL-BARSHA, Mohammad, Fayez (5) BARCHA, Mohammad, Fayez Position: Minister of State. Appointed in August 2020. Other Information: Gender: male. Listed on: 06/11/2020 Last Updated: 06/11/2020 Group ID: 14002.

7. HUSSEIN, Malloul

DOB: –/–/1950. POB: Al-Hasakah Governorate, Syria a.k.a: (1) AL-HUSSEIN, Malloul (2) AL-HUSSEIN, Maloul (3) HUSSEIN, Maloul Position: Minister of State. Appointed in August 2020 Other Information: Gender: male. Listed on: 06/11/2020 Last Updated: 06/11/2020 Group ID: 14003.

8. HADDAD, Mohammad Samir

DOB: –/–/1956. POB: Tartous, Syria Position: Minister of State. Appointed in August 2020 Other Information: Gender: male. Listed on: 06/11/2020 Last Updated: 06/11/2020 Group ID: 14004.

Links:

OFSI Notice

Council Implementing Regulation (EU) 2020/1649

OFAC today added the following persons:

AL-ALI, Nasr (Arabic: ناصر العلي) (a.k.a. AL-ALI, Naser; a.k.a. AL-ALI, Nasir; a.k.a. AL-ALI, Nasser; a.k.a. ALI, Nasser), Damascus, Syria; DOB 01 Feb 1961; POB Manbij, Aleppo, Syria; nationality Syria; Gender Male (individual) [SYRIA]. 
 
BIN AHMED RUSHDI AL-QATIRJI, Hussam (Arabic: حسام بن أحمد رشدي قاطرجي) (a.k.a. AL-QATIRJI, Hossam (Arabic: حسام القاطرجي); a.k.a. AL-QATIRJI, Hussam; a.k.a. KATARJI, Hussam; a.k.a. KATERJI, Hussam; a.k.a. KHATARJI, Hussam; a.k.a. KHATIRJI, Hussam; a.k.a. QATARJI, Hossam; a.k.a. QATERJI, Hussam; a.k.a. QATIRJI BIN AHMED RUSHDI, Hussam (Arabic: حسام قاطرجي بن احمد رشدي)), Syria; DOB 11 Jan 1982; POB Raqqa, Syria; nationality Syria; Gender Male (individual) [SYRIA]. 
 
IMAD AL-DIN AL-MADANI, Kamal (Arabic: كمال عمد الدين المدني) (a.k.a. AMAD AL-DIN AL-MADANI, Kamal; a.k.a. IMAD AL-DEEN AL-MADANI, Kamal), Beirut, Lebanon; DOB 08 Dec 1980; nationality Lebanon; Gender Male (individual) [SYRIA]. 
 
IMAD AL-DIN AL-MADANI, Tariq (Arabic: طارق عماد الدين المدني) (a.k.a. AMAD AL-DIN AL-MADANI, Tariq; a.k.a. IMAD AL-DEEN AL-MADANI, Tarek; a.k.a. IMAD AL-DIN AL-MADANI, Tareq), Beirut, Lebanon; DOB 12 Dec 1984; nationality Lebanon; Gender Male (individual) [SYRIA]. 
 
ISMAIL, Ghassan Jaoudat (Arabic: غسان جودت إسماعيل) (a.k.a. ISMAEL, Ghassan Jaoudat; a.k.a. SALAMEH, Ghassan), Aleppo, Syria; DOB 1960; POB Junaynat Ruslan, Darkoush, Drekish, Tartous, Syria; nationality Syria; Gender Male (individual) [SYRIA]. 
 
KHITI, Amer Taysir (Arabic: عامر تيسير خيتي) (a.k.a. KHEITI, Amer Tayseer; a.k.a. KHEITI, Amer Taysir), Damascus, Syria; DOB 31 Jul 1980; POB Douma, Syria; nationality Syria; alt. nationality Sudan; Gender Male (individual) [SYRIA]. 
 
TOUMEH BIN MOHAMMED, Nabil (Arabic: نبيل طعمة بن محمد) (a.k.a. MOHAMMED TOHMA, Nabil (Arabic: نبيل محمد طعمة); a.k.a. TOUMEH, Nabil; a.k.a. TU’MAH, Nabil; a.k.a. “BIN MOHAMMED TOAMEH, Nabil”; a.k.a. “TOHMA, Nabil” (Arabic: “نبيل طعمة”)), Damascus, Syria; DOB 04 Jan 1957; POB Damascus, Syria; nationality Syria; Gender Male (individual) [SYRIA]. 

and entities:

AL-RESAFA REFINERY COMPANY PRIVATE JSC (a.k.a. AL-RUSAFA REFINERY COMPANY (Arabic: شركة مصفاة الرصافة)), Al-Rusafa, Raqqa, Syria; Organization Established Date 09 Feb 2020; Organization Type: Manufacture of refined petroleum products [SYRIA]. 
 
ARFADA PETROLEUM PRIVATE JOINT STOCK COMPANY (Arabic: شركة أرفادا البترولية المساهمة المغفلة الخاصة) (a.k.a. ARFADA PETROLEUM COMPANY JSC; a.k.a. ARVADA PETROLEUM COMPANY JSC), Mashroua Dummar, Lot No. 13, Building 12/2, Damascus, Syria; Website https://www.arfada.com/; Organization Established Date 24 Apr 2018; Organization Type: Support activities for petroleum and natural gas extraction; Registration Number 18394 (Syria) [SYRIA] [SYRIA-CAESAR]. 
 
COASTAL REFINERY COMPANY PRIVATE JSC (a.k.a. AL-SAHEL REFINERY COMPANY; a.k.a. COAST REFINERY COMPANY (Arabic: شركة مصافة الساحل)), Tartous, Syria; Organization Established Date 09 Feb 2020; Organization Type: Manufacture of refined petroleum products [SYRIA]. 
 
KHITI HOLDING GROUP (Arabic: مجموعة خيتي القابضة) (a.k.a. KHEITI HOLDING GROUP; a.k.a. KHITI HOLDING COMPANY; a.k.a. KHITI HOLDING PRIVATE JSC), Mazzeh Highway, Damascus, Syria; Mashroa Domar, Damascus, Syria; Website http://www.khaitiholding.com; alt. Website http://www.khitiholding.com; Organization Established Date 2018; Organization Type: Activities of holding companies [SYRIA] (Linked To: KHITI, Amer Taysir). 
 
MILITARY CONSTRUCTION ESTABLISHMENT (Arabic: مؤسسة تنفيذ الإنشاءات العسكرية) (a.k.a. MILITARY CONSTRUCTION IMPLEMENTATION CORPORATION; a.k.a. “MATAA” (Arabic: “متاع“); a.k.a. “MCIC”), Kafarsouseh Circle, next to Al-Rafai Mosque, Damascus, Syria; Hama, Syria; Lattakia, Syria; Tartous, Syria; Jableh, Syria; Organization Established Date 1972; Organization Type: Construction of buildings; alt. Organization Type: Construction of roads and railways; alt. Organization Type: Construction of other civil engineering projects [SYRIA]. 
 
PRODUCTIVE PROJECTS ADMINISTRATION (Arabic: إدارة المشاريع الإنتاجية) (a.k.a. INTAJIA (Arabic: الانتاجية); a.k.a. INTAJIA PPA), P.O. Box 4703, Customs Free Zone, Damascus, Syria; Aleppo, Syria; Website http://intajia.sy; Organization Established Date 1973; Organization Type: Manufacture of pharmaceuticals, medicinal chemical and botanical products [SYRIA]. 
 
PUBLIC ESTABLISHMENT FOR REFINING AND DISTRIBUTION (Arabic: المؤسسة العامة لتكرير النفط و توزيع المشتقات النفطية) (a.k.a. GENERAL ORGANIZATION FOR REFINING AND DISTRIBUTION OF PETROLEUM PRODUCTS; a.k.a. THE PUBLIC ESTABLISHMENT FOR OIL REFINING AND THE DISTRIBUTION OF OIL DERIVATIVES), Tripoli Road, P.O. Box 342, Homs, Syria; Website http://perd.sy/; Organization Established Date 2009; Organization Type: Support activities for petroleum and natural gas extraction [SYRIA]. 
 
SALLIZAR SHIPPING SAL (Arabic: ساليزار شيبينغ ش.م.ل.), 1st Floor, Shuwairi Bldg., Boulevard Saib Salam, al-Masraa, Beirut Corniche, Lebanon; Organization Established Date 12 Apr 2018; Registration Number 1024992 (Lebanon) [SYRIA] [SYRIA-CAESAR]. 
 
SYRIAN MINISTRY OF PETROLEUM AND MINERAL RESOURCES (Arabic: وزارة النفط و الثروة المعدنية) (a.k.a. MINISTRY OF OIL AND MINERAL RESERVES), Dummar, P.O. Box 31483, Damascus, Syria; Website http://mopmr.gov.sy/ [SYRIA]. 
 
TOUMEH INTERNATIONAL GROUP (Arabic: مجموعة طعمة الدولية), Damascus, Syria; Organization Established Date 1975; Organization Type: Activities of holding companies [SYRIA] (Linked To: TOUMEH BIN MOHAMMED, Nabil). 

to its Syria sanctions program, the following person:

RUSTOM, Saqr (Arabic: صقر رستم) (a.k.a. AL-ROSTOM, Saqer Asaad; a.k.a. AL-RUSTOM, Saqr As’ad (Arabic: صقر أسعد الرستم); a.k.a. ROSTOM, Saker; a.k.a. RUSTOM, Sakkar; a.k.a. RUSTOM, Sakker; a.k.a. RUSTOM, Sakr; a.k.a. RUSTOM, Saqqar; a.k.a. RUSTOM, Saqqer), Homs, Syria; DOB 1974; POB Khirbet al-Hamam, Homs, Syria; nationality Syria; Gender Male; National ID No. 06110065397 (Syria) (individual) [SYRIA-EO13894]. 

and entity:

 
NATIONAL DEFENSE FORCES (Arabic: قوات الدفاع الوطني), Damascus, Syria; Organization Established Date 2012 [SYRIA-EO13894]. 

to its Syria-related sanctions program, and the following persons:

DENG, Zhonghua (Chinese Simplified: 邓中华), China; DOB Sep 1961; POB Changsha City, Hunan Province, China; nationality China; Gender Male (individual) [HK-EO13936]. 
 
LAU, Edwina (a.k.a. LAU, Chi Wai (Chinese Traditional: 劉賜蕙); a.k.a. LAU, Edwina Chi Wai; a.k.a. LIU, Cihui (Chinese Simplified: 刘赐蕙)), Hong Kong, China; DOB 29 Jul 1965; POB Hong Kong, China; nationality China; Gender Female; Passport HA1338416 (Hong Kong) expires 27 May 2015; National ID No. D5545251 (Hong Kong) (individual) [HK-EO13936]. 
 
LI, Jiangzhou (Chinese Simplified: 李江舟), Hong Kong, China; DOB Jan 1968; POB Qianshan City, Anhui Province, China; nationality China; Gender Male (individual) [HK-EO13936]. 
 
LI, Kwai-wah (Chinese Traditional: 李桂華) (a.k.a. LEE, Kwai-wah; a.k.a. LI, Guihua (Chinese Simplified: 李桂华); a.k.a. LI, Steve Kwai-wah), Flat B, 22 Floor, Block 30, Laguna City, Lam Tin, Kowloon City, Hong Kong, China; DOB 22 Nov 1964; POB Hong Kong, China; nationality China; Gender Male; Passport K06749109 (Hong Kong) expires 06 Sep 2028; National ID No. D4017081 (Hong Kong) (individual) [HK-EO13936]. 

to its Hong Kong-related sanctions program.

At some point, it would be easier to list everyone not sanctioned by OFAC…

Links:

OFAC Notice

Had to do the math to check if the 2 Syria-related designations were included…

Syria Sanctions Designations on the Anniversary of Assad’s Attack Against the People of Douma, Syria

PRESS STATEMENT

MICHAEL R. POMPEO, SECRETARY OF STATE

NOVEMBER 9, 2020

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Link:

State Department Press Release

Today, OFAC added the following entities:

KOREA CHOLSAN GENERAL TRADING CORPORATION (Cyrillic: ГЕНЕРАЛЬНАЯ ТОРГОВАЯ КОМПАНИЯ ЧХОЛСАН КНДР) (a.k.a. CHKHOLSAN; a.k.a. CHOLSAN TRADING COMPANY; a.k.a. CHOLSON LLC (Cyrillic: OOO ЧХОЛСАН)), Russia; Tongdaewon District, Pyongyang, Korea, North; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214; Organization Type: Construction of other civil engineering projects [DPRK3]. 
 
MOKRAN LLC (Cyrillic: OOO МОКРАН) (a.k.a. OBSCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU MOKRAN (Cyrillic: ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ МОКРАН); a.k.a. OOO MOKRAN), d. 15A liter A etazh / pom./ kom. 3/41/N-1, ul. Professora Kachalova, St. Petersburg 192019, Russia (Cyrillic: Улица Профессора Качалова, Дом 15A, Литер А, Эт/Пом/Ком 3/41/Н-1, Город Санкт-Петербург 192019, Russia); Ust-Izhora Village, Petrozavodsk Highway 23, Kolpinskiy District, St. Petersburg, Russia; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214; Organization Type: Construction of other civil engineering projects; Tax ID No. 7811489970 (Russia); Registration Number 1117847131643 (Russia) [DPRK3].

to its North Korea sanctions program, and updated these:

KOREA GENERAL CORPORATION FOR EXTERNAL CONSTRUCTION, Korea, North; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214 [DPRK3]. -to- KOREA GENERAL CORPORATION FOR EXTERNAL CONSTRUCTION (a.k.a. KOREA GENERAL COMPANY FOR EXTERNAL CONSTRUCTION; a.k.a. KOREA GENERAL CONSTRUCTION; a.k.a. “GENCO”; a.k.a. “KOGEN”; a.k.a. “ZENKO” (Cyrillic: “ЗЕНКО”)), Korea, North; Russia; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214; Organization Type: Construction of other civil engineering projects [DPRK3]. 
 
KOREA RUNGRADO GENERAL TRADING CORPORATION (a.k.a. RUNGRADO TRADE COMPANY), Korea, North; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214 [DPRK3]. -to- KOREA RUNGRADO GENERAL TRADING CORPORATION (a.k.a. RUNGRADO TRADE COMPANY; a.k.a. RYNRADO (Cyrillic: РЫНРАДО); a.k.a. RYNRADO GENERAL TRADING CORPORATION), Korea, North; Russia; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214; Organization Type: Construction of other civil engineering projects [DPRK3]. 
 
YANBIAN SILVERSTAR NETWORK TECHNOLOGY CO., LTD. (Chinese Simplified: 延边银星网络科技有限公司; Korean: 은성인터네트기술회사) (a.k.a. CHINA SILVER STAR INTERNET TECHNOLOGY COMPANY; a.k.a. SILVER STAR INTERNET TECHNOLOGY CORPORATION; a.k.a. UNSONG INTERNET TECHNOLOGY CORPORATION; a.k.a. YANBIAN SILVER STAR; a.k.a. YANBIAN SILVERSTAR), 20998B-26 Changbaishan East Road, Yanji, Jilin, China; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214 [DPRK3] [DPRK4]. -to- YANBIAN SILVERSTAR NETWORK TECHNOLOGY CO., LTD. (Chinese Simplified: 延边银星网络科技有限公司; Korean: 은성인터네트기술회사) (a.k.a. CHINA SILVER STAR INTERNET TECHNOLOGY COMPANY; a.k.a. SILVER STAR CHINA; a.k.a. SILVER STAR INTERNET TECHNOLOGY CORPORATION; a.k.a. UNSONG INTERNET TECHNOLOGY CORPORATION; a.k.a. YANBIAN SILVER STAR; a.k.a. YANBIAN SILVERSTAR; a.k.a. YANJI SILVER STAR NETWORK TECHNOLOGY CO. LTD.), 20998B-26 Changbaishan East Road, Yanji, Jilin, China; No. 213-214,  Building 2, Science and Technology Industrial Park, Yanji Development Zone, China; Chang Bai Shan Dong Lu, 20998B-26Hao, Yanji, Jilin 133000, China; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214; Unified Social Credit Code (USCC) 91222401MA0Y31E659 (China) [DPRK3] [DPRK4]. 

Additionally, the following Syria-related designation was updated:

RUSTOM, Saqr (Arabic: صقر رستم) (a.k.a. AL-ROSTOM, Saqer Asaad; a.k.a. AL-RUSTOM, Saqr As’ad (Arabic: صقر أسعد الرستم); a.k.a. ROSTOM, Saker; a.k.a. RUSTOM, Sakkar; a.k.a. RUSTOM, Sakker; a.k.a. RUSTOM, Sakr; a.k.a. RUSTOM, Saqqar; a.k.a. RUSTOM, Saqqer), Homs, Syria; DOB 1974; POB Khirbet al-Hamam, Homs, Syria; nationality Syria; Gender Male; National ID No. 06110065397 (Syria) (individual) [SYRIA-EO13894]. -to- RUSTOM, Saqr (Arabic: صقر رستم) (a.k.a. AL-ROSTOM, Saqer Asaad; a.k.a. AL-RUSTOM, Saqr As’ad (Arabic: صقر أسعد الرستم); a.k.a. ROSTOM, Saker; a.k.a. RUSTOM, Sakkar; a.k.a. RUSTOM, Sakker; a.k.a. RUSTOM, Sakr; a.k.a. RUSTOM, Saqqar; a.k.a. RUSTOM, Saqqer), Homs, Syria; DOB 1974; POB Khirbet al-Hamam, Homs, Syria; nationality Syria; Gender Male (individual) [SYRIA-EO13894]. 

Link:

OFAC Notice

Today, Swiss authorities added the following persons to their Syria travel & financial sanctions:

SSID: 200-43870 Name: Bassam Tou’ma

Sex: M DOB: 1969 POB: Safita, Syrian Arab Republic Good quality a.k.a.: Tu’ma Justification: Minister of oil and mineral resources. Appointed in Aug 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression against the civilian population. Modifications: Listed on 19 Nov 2020

SSID: 200-43878 Name: Hassan Ghabache

Sex: M DOB: 1971 POB: Damascus, Syrian Arab Republic Good quality a.k.a.: Ghobash (Al-Ghabbash)

Justification: Minister of health. Appointed in Aug 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression against the civilian population. Modifications: Listed on 19 Nov 2020

SSID: 200-43885 Name: Ziyad Sabbagh

Sex: M DOB: 1960 POB: Aleppo, Syrian Arab Republic

Justification: Minister of Industry. Appointed in Aug 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression against the civilian population. Modifications: Listed on 19 Nov 2020

SSID: 200-43891 Name: Mohammad Hassan Qatana

Sex: M POB: Damascus, Syrian Arab Republic

Justification: Minister of Agriculture and Agrarian reform. Appointed in Aug 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression against the civilian population. Modifications: Listed on 19 Nov 2020

SSID: 200-43896 Name: Ghassan Zamel

Sex: M DOB: 1963 POB: Damascus, Syrian Arab Republic Good quality a.k.a.: Al-Zamil (Al-Zamel)

Justification: Minister of Electricity. Appointed in Aug 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression against the civilian population. Modifications: Listed on 19 Nov 2020

SSID: 200-43903 Name: Mohamad Fayez Barcha

Sex: M DOB: 1955 POB: Damascus, Syrian Arab Republic Good quality a.k.a.: a) Mohammad b) Al-Barsha (Al-Barasha)

Justification: Minister of State. Appointed in Aug 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression against the civilian population. Modifications: Listed on 19 Nov 2020

SSID: 200-43910 Name: Malloul Hussein

Sex: M DOB: 1950 POB: Al-Hasakah Governorate, Syrian Arab Republic Good quality a.k.a.: a) Maloul b) Al-Hussein

Justification: Minister of State. Appointed in Aug 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression against the civilian population. Modifications: Listed on 19 Nov 2020

SSID: 200-43918 Name: Mohammad Samir Haddad

Sex: M DOB: 1956 POB: Tartous, Syrian Arab Republic

Justification: Minister of State. Appointed in Aug 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression against the civilian population. Modifications: Listed on 19 Nov 2020

Links:

FINMA Notice

Data files of updates – PDF, XML

Today, OFAC added the following persons:

AL-KINAYEH, Lina Mohammed Nazir (Arabic: لينا محمد نذير الكناية) (a.k.a. AL-CANAIYA, Leena Muhammad Nathir; a.k.a. AL-KINAYA, Lina Muhammed Nazir; a.k.a. AL-KINAYEH, Leena; a.k.a. AL-KINAYEH, Lina (Arabic: لينا الكناية); a.k.a. AL-KINAYEH, Lina Mohammad Natheer; a.k.a. KINAYEH, Lina (Arabic: لينا كناية); a.k.a. KNAYA, Lina; a.k.a. KNIYA, Lina), Al-Zahiriya, Northern Tripoli, Lebanon; DOB 20 Jan 1980; nationality Lebanon; alt. nationality Syria; Gender Female; National ID No. 000036055655(Lebanon) (individual) [SYRIA]. 
 
MASOUTI, Mohammed Hammam Mohammed Adnan (Arabic: محمد همام محمد عدنان مسوتي) (a.k.a. HUMAM, Msuti; a.k.a. MASOUTI BIN MOHAMMED ADNAN, Mohammed Humam (Arabic: محمد همام مسوتي بن محمد عدنان); a.k.a. MASOUTI, Mohammad Humam; a.k.a. MASOUTI, Mohammad Hussam Mohammad Adnan; a.k.a. MASOUTI, Mohammed Hammam; a.k.a. MASOUTI, Mohammed Humam Mohammed Adnan; a.k.a. MSOUTI, Mohammad Humam Mohammad Adnan), Damascus, Syria; DOB 1976; POB Damascus, Syria; nationality Syria; Gender Male (individual) [SYRIA]. 

and entities:

AL-AMER DEVELOPMENT AND REAL ESTATE INVESTMENT (Arabic: العامرللتطويروالاستثمارالعقاري) (a.k.a. AL-AMER DEVELOPMENT & REAL ESTATE INVESTMENT; a.k.a. AL-AMER DEVELOPMENT AND REAL ESTATE INVESTMENT COMPANY; a.k.a. AL-AMER REAL ESTATE DEVELOPMENT AND INVESTMENT LLC; a.k.a. “AL-AMER DEVELOPMENT”), Mezzeh Villas, Damascus, Syria; Organization Established Date 19 Dec 2019; Organization Type: Real estate activities with own or leased property; Registration Number 19096 (Syria) [SYRIA] (Linked To: KHITI, Amer Taysir). 
 
AL-AMER FOR MANUFACTURE OF CONCRETE AND FLAGSTONE (Arabic: العامر لصناعة المجبول البيتوني والبلوك والبلاط) (a.k.a. AL-AMER FOR CONCRETE, BLOCK AND TILE MANUFACTURING LLC; a.k.a. AL-AMER FOR MANUFACTURE OF CONCRETE, FLAGSTONE, LIMITED LIABILITY), Rural Damascus, Syria; Organization Established Date 04 Nov 2019; Organization Type: Manufacture of articles of concrete, cement and plaster; Registration Number 12428 (Syria) [SYRIA]. 
 
AL-AMER FOR MANUFACTURE OF PLASTIC (Arabic: العامرلصناعة البلاستيك) (a.k.a. ALAMER FOR MANUFACTURE OF PLASTIC LIMITED LIABILITY; a.k.a. AL-AMER PLASTIC INDUSTRY LLC), Rural Damascus, Syria; Organization Established Date 04 Nov 2019; Organization Type: Manufacture of plastics products; Registration Number 12427 (Syria) [SYRIA]. 
 
AL-LAYTH ALZAHABE TRANSPORTATION AND SHIPPING SERVICES (Arabic: الليث الذهبي لخدمات النقل والشحن) (a.k.a. ALLAYTH ALZAHABE (Arabic: الليث الذهبي); a.k.a. GOLDEN LAITH FREIGHT FORWARD SERVICES; a.k.a. GOLDEN LEIH TRANSPORTATION & SHIPMENT SERVICES L.L.C.; a.k.a. GOLDEN LEIH TRANSPORTATION AND SHIPMENT SERVICES L.L.C.; a.k.a. GOLDEN LEITH FOR TRANSPORTATION AND SHIPPING SERVICES), Damascus, Syria; Organization Established Date 26 May 2019; Registration Number 12388 (Syria) [SYRIA] (Linked To: KHITI HOLDING GROUP). 
 
CENTRAL BANK OF SYRIA (Arabic: مصرف سوریا المركزي) (a.k.a. BANQUE CENTRALE DE SYRIE; a.k.a. MASRIF SOURIYA AL-MARKAZI), P.O. Box 2254, Altajrida Al Mughrabia Square, Damascus, Syria; Sabaa Bahrat Square, Damascus, Syria; SWIFT/BIC CBSYSYDA; Organization Established Date 28 Mar 1953; alt. Organization Established Date 01 Aug 1956; Organization Type: Central banking [SYRIA]. 
 
GOOD LAND COMPANY (Arabic: شركة ارض الخير) (a.k.a. ARD AL-KHAIR INTERNATIONAL COMPANY; a.k.a. ARD AL-KHER INTERNATIONAL COMPANY; a.k.a. GOOD LAND INTERNATIONAL COMPANY (Arabic: شركة ارض الخير الدولية); a.k.a. GOOD LAND INTERNATIONAL COMPANY FOR THE IMPORTING AND EXPORTING OF VEGETABLES AND FRUIT (Arabic: شركة ارض الخير الدولية لاستيراد وتصدير الخضار و الفواكة); a.k.a. GOOD LAND LIMITED LIABILITY COMPANY), Duma, Syria; Oman; Jordan; Egypt; Organization Established Date 1995; alt. Organization Established Date 2016; Organization Type: Wholesale of food, beverages and tobacco; Registration Number 10845 (Syria) [SYRIA] (Linked To: KHITI, Amer Taysir). 
 
LETIA COMPANY (Arabic: شركة ليتيا) (a.k.a. LETIA JOINT-STOCK COMPANY L.L.C.; a.k.a. LETIA LIMITED LIABILITY COMPANY; a.k.a. LITIA COMPANY), Damascus, Syria; Organization Established Date 10 Jan 2019; Organization Type: Manufacture of medical and dental instruments and supplies [SYRIA]. 
 
LIA COMPANY (Arabic: شركة ليا) (a.k.a. LIA CO L.L.C.; a.k.a. “LEAH COMPANY”), Damascus, Syria; Organization Established Date 30 Jan 2011 [SYRIA] (Linked To: MASOUTI, Mohammed Hammam Mohammed Adnan). 
 
POLYMEDICS LLC (Arabic: شركة الطبیات المتعددة) (a.k.a. “POLYMEDICS COMPANY”), Damascus, Syria; Organization Established Date 19 Oct 2011; Organization Type: Wholesale of other machinery and equipment [SYRIA] (Linked To: MASOUTI, Mohammed Hammam Mohammed Adnan). 
 
SOURAN COMPANY (Arabic: شركة سوران) (a.k.a. SORAN COMPANY), Damascus, Syria; Organization Established Date 03 Sep 2018; Organization Type: Other telecommunications activities; alt. Organization Type: Wholesale of electronic and telecommunications equipment and parts [SYRIA] (Linked To: MASOUTI, Mohammed Hammam Mohammed Adnan). 

under its Syria sanctions program, and the following persons:

AL-AKHRAS, Eyad (Arabic: اياد الاخرس) (a.k.a. AKHRAS, Iyad), 34 Allan Way, London, United Kingdom; DOB Dec 1980; POB London, United Kingdom; nationality United Kingdom; alt. nationality Syria; Gender Male; National ID No. 116544570001 (United Kingdom) (individual) [SYRIA-EO13894]. 
 
AL-AKHRAS, Fawaz (Arabic: فواز الاخرس) (a.k.a. AKHRAS, Fawwaz), 34 Allan Way, London, United Kingdom; DOB Sep 1946; POB Homs, Syria; nationality United Kingdom; alt. nationality Syria; Gender Male (individual) [SYRIA-EO13894]. 
 
AL-AKHRAS, Firas (Arabic: فراس الاخرس) (a.k.a. AKHRAS, Feras; a.k.a. FAWAZ AKHRAS, Firas), 34 Allan Way, London, United Kingdom; DOB Mar 1978; POB London, United Kingdom; nationality United Kingdom; alt. nationality Syria; Gender Male; National ID No. 114671230001 (United Kingdom) (individual) [SYRIA-EO13894]. 
 
AL-AKHRAS, Sahar Otri (Arabic: سحر عطري الاخرس) (a.k.a. AKHRAS, Sahar; a.k.a. ATRI, Sahar; a.k.a. ITRI, Sahar; a.k.a. OTRI, Sahar; a.k.a. UTRI, Sahar), 34 Allan Way, London, United Kingdom; DOB Nov 1949; nationality United Kingdom; alt. nationality Syria; Gender Female (individual) [SYRIA-EO13894]. 
 
MOULHEM, Kifah (Arabic: كفاح ملحم) (a.k.a. AL-MILHEM, Kifah; a.k.a. MELHEM, Kifah; a.k.a. MILHEM, Kifah; a.k.a. MOULHIM, Kifah; a.k.a. MULHEM, Kifah; a.k.a. MULHIM, Kifah), Damascus, Syria; DOB 28 Nov 1961; POB Junayrat Ruslan, Tartous, Syria; nationality Syria; Gender Male (individual) [SYRIA-EO13894]. 

under its Syria-related sanctions program. It also updated a Syria-related designation:

AL-ASSAD, Asma (Arabic: اسماء الاسد) (a.k.a. AKHRAS, Asma; a.k.a. AL-AKHRAS, Asma), Damascus, Syria; DOB 11 Aug 1975; POB Acton, United Kingdom; nationality Syria; alt. nationality United Kingdom; Gender Female (individual) [SYRIA-EO13894]. -to- AL-ASSAD, Asma (Arabic: اسماء الاسد) (a.k.a. AKHRAS, Asma; a.k.a. AKHRAS, Emma; a.k.a. AL-AKHRAS, Asma; a.k.a. AL-ASSAD, Asmaa; a.k.a. FAWAZ AL-AKHRAS, Asma (Arabic: اسماء فواز الاخرس)), Damascus, Syria; DOB 11 Aug 1975; POB Acton, United Kingdom; nationality Syria; alt. nationality United Kingdom; Gender Female (individual) [SYRIA-EO13894]. 

Additionally, it added 3 new Frequently Asked Questions – 866:

867:

and 868:

And the State Department said this:

Syria Sanctions Designations on the Anniversary of UN Security Council Resolution 2254

PRESS STATEMENT

MICHAEL R. POMPEO, SECRETARY OF STATE

DECEMBER 22, 2020

Share

as did Treasury:

Links:

OFAC Notice

FAQs 866, 867, 868

State Department Press Release

Treasury Department Press Release

NCB, based in Jeddah, Saudi Arabia, paid the settlement for 13 apparent violations of the Sudan and Syria-related sanctions in which the transactions went through the U.S. financial system between November 2011 and late August 2014. The non-egregious violations were voluntarily self-disclosed for 8 Syria-related violations, but not self-disclosed for the 5 Sudanese ones. When you consider them all, the base penalty was $1,814,854.

What happened

Between November 7, 2011 and August 28, 2014, NCB processed, directly or indirectly, 13 U.S. dollar (USD) transactions totaling $5,918,560 to or through the United States in circumstances where a benefit of NCB’s service was received by Sudanese or Syrian counterparties, or that involved goods originating in or transiting through Sudan or Syria. None of the Sudanese or Syrian parties was a customer of NCB. These transactions were in apparent violation of the Sudanese Sanctions Regulations (“SSR”), 31 C.F.R. § 538.205,1 and section 2(b) of Executive Order (E.O.) 13582 of August 17, 2011,2 respectively. The Apparent Violations began in late 2011, after the bank had started to implement more robust compliance measures intended to modernize and upgrade its compliance controls, including those relating to sanctions screening and OFAC sanctions compliance.

The calculation: the General Factors

The aggravating factors:

(1) NCB conferred substantial economic benefit to U.S.-sanctioned parties and caused significant

harm to the integrity of U.S. sanctions programs and their associated policy objectives by allowing sanctioned parties to conduct business in or through the United States for a number of years; and

(2) NCB is a large and commercially sophisticated financial institution.

and the mitigating ones:

(1) NCB did not act with willful intent to violate U.S. sanctions law or with a reckless disregard for its U.S. sanctions obligations;

(2) NCB has no prior sanctions history, including having not received a penalty notice or Finding of Violation from OFAC in the five years preceding the date of the earliest transaction giving rise to the apparent violations;

(3) NCB cooperated with OFAC’s investigation into the Apparent Violations, including by conducting an extensive transaction review and entering into a statute of limitations tolling agreement with multiple extensions;

(4) Most of the Syria-related Apparent Violations occurred shortly after the imposition of relevant prohibitions; and

(5) NCB enhanced compliance controls in response to past weaknesses and the subsequent Apparent Violations, including the following:

• Replaced its Board of Directors and senior executives and enhanced its compliance program by implementing new sanctions screening software and new training procedures for bank personnel;

• Implemented internal policies that require payment and non-payment messages to be transparent, in line with Basel requirements and FATF recommendations, and that prohibit the omission, deletion or alteration of information in the payment messages or orders;

• Required screening of all payments against international sanctions lists, including OFAC lists;

• Implemented an Anti-Money Laundering Department that is tasked with sanctions compliance and countering illicit finance, including money laundering and terrorist financing;

• Required prospective customer account openings to be subjected to substantial due diligence, including Compliance Department approval of any account opening, and restricted account openings to only residents of Saudi Arabia; and

• Prohibited the opening of USD accounts for any Sudanese customers or financial institutions.

The lesson to learn…

This enforcement action highlights the importance of ensuring that sanctions compliance policies and procedures address both direct and indirect sanctions compliance risks, and in particular, highlights the importance of implementing strong remedial measures in response to sanctions program lapses.

Admittedly skimpy…

Link:

OFAC Enforcement Information

That is not a typo… Mr. Watchlist meant to type “disinformation.” Read the details and I think you’ll understand why/…

Union de Banques Arabes et Francaises (UBAF) committed 127 apparent non-egregious, voluntarily self-disclosed violations of sanctions imposed on sanctioned Syrian financial institutions between August 2011 and April 2013. These violated the Syrian (Executive Order 13582) and/or Weapons of Mass Destruction (Executive Order 13382) sanctions.

What UBAF did

In total, UBAF engaged in 127 Apparent Violations. This includes UBAF’s processing of 114 internal transfers on behalf of Syrian entities totaling $1,297,651,825.61 that were followed by approximately 114 corresponding funds transfers through a U.S. bank. For 45 of the 114 internal transfers, UBAF processed a USD transfer between two of its clients—one sanctioned Syrian entity and one non- sanctioned client—on UBAF’s own books. UBAF then processed one or more USD transfers on behalf of the non-sanctioned client that cleared through a U.S. bank and whose transaction dates and amounts correlated closely to the related internal transfers reflected on UBAF’s books. For the remaining 69 of 114 internal transfers, UBAF conducted a foreign exchange (FX) transaction with a sanctioned Syrian customer on UBAF’s books, debiting an account in one currency and crediting the same sanctioned customer’s account in another currency. UBAF then conducted a U.S.-cleared FX transaction with a non-sanctioned third party that correlated closely with the original FX transaction involving the sanctioned customer.

The remaining 13 Apparent Violations were either “back-to-back” letter of credit transactions or other trade finance transactions involving sanctioned Syrian parties, all of which were processed through a U.S. bank. For the back-to-back letter of credit transactions, a sanctioned Syrian entity was the beneficiary of export letters of credit or the applicant for import letters of credit that did not involve USD clearing, but the intermediary entered into or received one or more corresponding USD letters of credit to purchase or sell the same goods. For the other trade finance transactions, UBAF either issued a USD- denominated letter of credit on behalf of a sanctioned party or confirmed a USD-denominated letter of credit issued by a sanctioned bank and paid on the letter of credit through a U.S.-cleared transaction.

Accordingly, between August 2011 and April 2013, UBAF processed 127 transactions, totaling $2,079,339,943.52, in apparent violation of Executive Order 13582 of August 17, 2011, “Blocking Property of the Government of Syria and Prohibiting Certain Transactions with Respect to Syria” (“E.O. 13582”), and Executive Order 13382 of July 1, 2005, “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters” (“E.O. 13382”). UBAF’s actions during this time period demonstrated knowledge of OFAC sanctions laws, but it incorrectly believed that avoiding direct USD clearing on behalf of sanctioned parties was sufficient; thus, the bank acted recklessly by failing to exercise a minimal degree of caution or care in accounting for the risks associated with continuing to provide USD-based services to OFAC-sanctioned parties.

Penalty & General Factors

The statutory maximum civil monetary penalty applicable in this matter is $4,158,679,887.04. OFAC determined, however, that UBAF voluntarily self-disclosed the Apparent Violations and that the Apparent Violations constitute a non-egregious case. Accordingly, under OFAC’s Economic Sanctions Enforcement Guidelines (“Enforcement Guidelines”), the base civil monetary penalty amount applicable in this matter is $15,875,000. The settlement amount of $8,527,500 reflects OFAC’s consideration of the General Factors under the Enforcement Guidelines.

OFAC determined the following to be aggravating factors:

(1) UBAF demonstrated a reckless disregard for its U.S. sanctions compliance obligations when it continued to provide USD services to sanctioned Syrian parties after the August 2011 expansion of U.S. sanctions on Syria without properly identifying and managing the relevant sanctions compliance risks that providing those services posed to the bank;

(2) UBAF management had actual knowledge of the conduct giving rise to the Apparent Violations; and

(3) UBAF conferred significant economic benefit to U.S.-sanctioned parties and caused significant harm to the integrity of U.S. sanctions programs and their associated policy objectives.

OFAC determined the following to be mitigating factors:

(1) The majority of the Apparent Violations occurred in late 2011, following the implementation of Executive Order 13582 on August 18, 2011, which significantly expanded U.S. sanctions against Syria;

(2) UBAF had a compliance program in place at the time of the apparent violations;

(3) UBAF voluntarily self-disclosed the Apparent Violations to OFAC and cooperated with OFAC’s investigation of the Apparent Violations by entering into a tolling agreement and agreeing to extend the agreement multiple times;

(4) UBAF has not received a penalty notice or Finding of Violation from OFAC in the five years preceding the earliest date of the transactions giving rise to the Apparent Violations; and

(5) UBAF has represented to OFAC that it has invested substantial resources in improving its compliance program and undertook several remedial measures in response to the Apparent Violations. These measures include:

• UBAF adopted a new Financial Security Charter on September 12, 2013, based on the compliance policies of its largest shareholder, a large and sophisticated financial institution, at the invitation and with the support of the shareholder. UBAF automatically adopts all of this financial institution’s sanctions policies, and also utilizes its filtering software and supplemental lists to screen transactions. This includes screening the client database, an anti-stripping module, negative news research, risk database research, vessel screening, and country screening.

• UBAF provides both in-person and e-learning training for all employees, both at onboarding and on a continuing basis. The e-learning program was developed with the above-mentioned financial institution and includes several yearly trainings.

• UBAF completed a review of its own business lines, which resulted in the termination of certain services that were deemed high compliance risks. UBAF exited its relationships with certain high-risk banks, exited business with Sudan and Syria in all currencies, and closed a foreign subsidiary for risk-related reasons.

• UBAF set up a Compliance Committee, composed of senior managers, which meets regularly to monitor follow-up on promised actions by member departments.

The lesson you should learn

Financial institutions that maintain accounts for entities domiciled in jurisdictions that become subject to comprehensive sanctions should assess the risk that may arise by continuing to provide services to those entities, particularly with respect to USD-denominated transactions that directly or indirectly clear through the U.S. financial system.

Mr. Watchlist’s Commentary

How does over $2 billion of value, over 127 transactions, over more than a year and a half, constitute “non-egregious”? Management knew, there was recklessness, there was significant benefit, over an extended period of time.

The justification is that UBAF had a compliance program, and that most of the damage occurred pretty soon after E.O. 13582 was passed in August 2011.

Well, Syria sanctions date back to 2004 (at least that’s the date of the earliest E.O. on the OFAC Syria sanctions page) – and UBAF is not a small bank (not if they offered correspondent services to others), nor a new one. If they had a sanctions compliance function (which it does not say – it says “compliance”), why were they not keeping up to date with changes in Syria sanctions? OFAC did have a website back then…

I see that UBAF is headquartered in Paris…with about 2 billon EUR in assets as of 2018, and was founded in 1970.

I think it is more likely that the penalty amount and the way the enforcement action was presented was negotiated to minimize upsetting France….

Who’s with me?

Link:

OFAC Enforcement Information

Amendments to the Consolidated List

44 individuals and entities have been amended in the Consolidated List of Asset Freeze Targets.

This follows an update to the UK Sanctions List.

Amendments have been made to entries in the Belarus, Burma, Chemical Weapons, Democratic People’s Republic of Korea, Democratic Republic of the Congo, Libya, Russia and Syria financial sanctions regimes.

OFSI’s consolidated list of asset freeze targets has been updated to reflect these changes.

Today, Swiss authorities added:

SSID: 200-44361 Name: Faisal Mekdad

Sex: M DOB: 1954 POB: Ghasm, Daraa Governorate, Syrian Arab Republic Good quality a.k.a.: a) Fayçal b) al-Mekdad (Meqdad, al-Meqdad)

Justification: Minister of Foreign Affairs. Appointed in Nov 2020. As a Government Minister, shares responsibility for the Syrian regime’s violent repression against the civilian population. Modifications: Listed on 3 Feb 2021

to their Syria sanctions program.

Link:

FINMA Notice

Data files of updates – PDF, XML

Joint statement of Canada and the Kingdom of the Netherlands regarding their cooperation in holding Syria to account

March 12, 2021 – Ottawa, Ontario – Global Affairs Canada

The Honourable Marc Garneau, Minister of Foreign Affairs of Canada, and Stef Blok, Minister of Foreign Affairs of the Kingdom of the Netherlands, today issued the following statement:

“10 years after the protests in Syria and their subsequent violent repression, gross human rights violations persist to this day. Syrians have been tortured, murdered, forcibly disappeared, and subjected to chemical weapon attacks. The Syrian regime has cruelly and systematically repressed and committed crimes against its own population, causing unimaginable suffering. Over the past decade, it is estimated that over 200,000 Syrian civilians have died in the conflict and another 100,000 people are missing. More than six million Syrians, who almost lost everything, are displaced and 5.5 million have fled all over the globe.

“In the face of these grave international law violations, Canada and the Kingdom of the Netherlands will take further steps together to hold Syria to account, including for human rights violations and torture in particular. We will hold the Assad regime accountable for its violations of the UN Convention against Torture and demand justice for the victims of the regime’s horrific crimes.

“On 18 September 2020, the Netherlands invoked Syria’s responsibility for human rights violations, specifically holding Syria responsible for torture under the UN Convention against Torture. On 3 March 2021, Canada took the same step.

“We reminded Syria of its international obligations to cease the violations and reiterated our calls to end the impunity and uphold justice.

“We are committed to making a genuine attempt to resolve our dispute with Syria through negotiations. However, should this not result in a timely resolution of the dispute, we will explore the possibility of joint legal action under the Convention against Torture.  

“We reaffirm our call to refer the situation in Syria to the International Criminal Court, and commend efforts towards justice at the international level. We remain committed to upholding the rules-based international order and call on all States and the international community to support accountability efforts for Syria, including joining our efforts.”

Today, OFSI added the following 6 persons:

1. AL-QATIRJI, Muhammad Bara

DOB: 10/11/1976. POB: Raqqah, Syria a.k.a: (1) ABU BARA (2) AL-QATARJI, Abu, al- Bara (3) AL-QATARJI, Bara (4) AL-QATARJI, Bara, Ahmad (5) AL-QATARJI, Muhammad (6) AL-QATARJI, Muhammad, Bara, Ahmad, Rushdi (7) AL-QATARJI, Muhammad, Nur, al-Din (8) KATARJI, Abu, al-Bara (9) KATARJI, Bara (10) KATARJI, Bara, Ahmad (11) KATARJI, Muhammad (12) KATARJI, Muhammad, Bara, Ahmad, Rushdi (13) KATARJI, Muhammad, Nur, al-Din (14) KHATARJI, Abu, al-Bara (15) KHATARJI, Bara (16) KHATARJI, Bara, Ahmad (17) KHATARJI, Muhammad (18) KHATARJI, Muhammad, Bara, Ahmad, Rushdi (19) KHATARJI, Muhammad, Nur, al-Din (20) KHATIRJI, Abu, al- Bara (21) KHATIRJI, Bara (22) KHATIRJI, Bara, Ahmad (23) KHATIRJI, Muhammad (24) KHATIRJI, Muhammad, Bara, Ahmad, Rushdi (25) KHATIRJI, Muhammad, Nur, al-Din (26) QATARJI, Abu, al-Bara (27) QATARJI, Bara (28) QATARJI, Bara, Ahmad (29) QATARJI, Muhammad (30) QATARJI, Muhammad, Bara, Ahmad, Rushdi (31) QATARJI, Muhammad, Nur, al-Din (32) QATIRJI, Abu, al-Bara (33) QATIRJI, Bara (34) QATIRJI, Bara, Ahmad (35) QATIRJI, Muhammad (36) QATIRJI, Muhammad, Bara, Ahmad, Rushdi (37) QATIRJI, Muhammad, Nur, al-Din (38) QATRJI, Abu, al-Bara (39) QATRJI, Bara (40) QATRJI, Bara, Ahmad (41) QATRJI, Muhammad (42) QATRJI, Muhammad, Bara, Ahmad, Rushdi (43) QATRJI, Muhammad, Nur, al-Din Nationality: Syria National Identification no: 11010046398 Other Information: (UK Sanctions List Ref): SYR0375 (UK Statement of Reasons): Prominent and influential businessperson operating across multiple sectors of the Syrian economy. Qatirji supports and benefits from the regime including through enabling, and profiting from, trade deals with the regime in relation to oil and wheat. (Gender): Male Listed on: 15/03/2021 Last Updated: 15/03/2021 Group ID: 14068.

2. AL-MIQDAD, Faisal

Title: Dr DOB: 05/02/1954. POB: Daraa, Syria a.k.a: (1) AL-MEKDAD, Fayçal (2) AL- MEKDAD, Fayssal (3) AL-MEQDAD, Fayçal (4) AL-MEQDAD, Fayssal (5) MEKDAD, Fayçal (6) MEKDAD, Fayssal (7) MEQDAD, Fayçal (8) MEQDAD, Fayssal (9) MIQDAD, Fayçal (10) MIQDAD, Fayssal Nationality: Syria Position: Minister of Foreign Affairs and Expatriates Other Information: (UK Sanctions List Ref): SYR0376 (UK Statement of Reasons): Minister of Foreign Affairs. Appointed in November 2020. As a Government Minister shares responsibility for the Syrian regime’s violent repression against the civilian population. (Gender): Male Listed on: 15/03/2021 Last Updated: 15/03/2021 Group ID: 14069.

3. AL-SHIBL, Luna

DOB: 01/09/1975. POB: Suweida, Syria a.k.a: (1) AL CHEBEL, Luna (2) AL CHEBIL, Luna (3) AL SHEBEL, Luna (4) AL SHEBIL, Luna (5) AL SHIBIL, Luna (6) AL SHIBL, Luna (7) ALSHEBEL, Luna (8) CHEBEL, Luna (9) CHEBIL, Luna (10) SHEBEL, Luna (11) SHEBIL, Luna (12) SHIBIL, Luna (13) SHIBL, Luna Nationality: Syria Position: Media Adviser to President Assad Other Information: (UK Sanctions List Ref): SYR0377 (UK Statement of Reasons): Adviser to President Assad and a prominent member of his inner circle. As Media Adviser to the President she supports the Syrian regime, which relies on disinformation and a lack of media freedom to repress the civilian population. She is also associated with the Syrian regime through her role as an adviser. (Gender): Female Listed on: 15/03/2021 Last Updated: 15/03/2021 Group ID: 14070.

4. ALIAA, Malik

Title: Major General POB: Tatrous, Syria a.k.a: ALIA, Malek Nationality: Syria Position: Commander of the Republican Guard Other Information: (UK Sanctions List Ref): SYR0378 (UK Statement of Reasons): Major General and Commander of the Republican Guard as of January 2021, and former Commander of the Republican Guard’s 30th Division. Responsible for the violent repression of the civilian population by troops under his command, particularly during the increased violence of the offensives on north-west Syria of 2019-2020. (Gender): Male Listed on: 15/03/2021 Last Updated: 15/03/2021 Group ID: 14071.

5. IBRAHIM, Yasser Hussein

DOB: 09/04/1983. POB: Damascus, Syria a.k.a: (1) IBRAHIM, Yasar (2) IBRAHIM, Yassar Nationality: Syria Other Information: (UK Sanctions List Ref):SYR0379 (UK Statement of Reasons): Prominent and influential businessperson and financier to President Assad, operating across multiple sectors of the Syrian economy. The Ibrahim family, led by Yasser Ibrahim, is associated with the Assad regime, and acts as a front for Bashar and Asma Assad’s personal hold on the Syrian economy, whilst millions of Syrians are food insecure. (Gender): Male Listed on: 15/03/2021 Last Updated: 15/03/2021 Group ID: 14072.

6. SALAH, Zaid

Title: Major General POB: Latakia, Syria a.k.a: SALEH, Zaed Nationality: Syria Position: Commander of the Syrian Army’s 5th Corps Other Information: (UK Sanctions List Ref): SYR0380 (UK Statement of Reasons): Major General and since January 2018 Commander of the Syrian Army’s 5th Corps, and previously commanded the Republican Guard’s 30th Division. Responsible for the violent repression of the civilian population by troops under his command, particularly during the increased violence of the Idlib/Hama offensive which began in April 2019. (Gender): Male Listed on: 15/03/2021 Last Updated: 15/03/2021 Group ID: 14073.

And the UK government issued the following news story:

Links:

OFSI Notice

UK News Release

Link:

OFAC Notice

FAQs 884, 885

Today, OFAC added the following persons:

AKAR, Ezzat Youssef (Arabic: عزت يوسف أكار) (a.k.a. AKAR, Izzat; a.k.a. AKAR, Izzat Youssef; a.k.a. AKKAR, Izzat Yusif), Al-Kyam Hayy al-Sharqi, Marjayun, Al-Nabtiyah, Lebanon; DOB 01 Nov 1967; POB Al-Kiyam, Lebanon; nationality Lebanon; Additional Sanctions Information - Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Gender Male (individual) [SDGT] (Linked To: AL-QARD AL-HASSAN ASSOCIATION). 
 
DAHER, Ibrahim Ali (Arabic: ابراهيم علي ضاهر) (a.k.a. DAHIR, Ibrahim), Serhal Building, 1st Floor, Daccache Street, Haret Hreik, Baabda, Lebanon; Blida, Marjayoun, Nabatiyeh, Lebanon; DOB 04 Jul 1964; nationality Lebanon; Additional Sanctions Information - Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Gender Male; National ID No. 2562031 (Lebanon) (individual) [SDGT] (Linked To: HIZBALLAH). 
 
GHARIB, Abbas Hassan (Arabic: عباس حسن غريب) (a.k.a. "GHARIB, Abbass"), Tayir Harfa, Tyre, South Lebanon, Lebanon; DOB 25 Sep 1969; POB Tayir Harfa, Lebanon; nationality Lebanon; Additional Sanctions Information - Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Gender Male (individual) [SDGT] (Linked To: AL-QARD AL-HASSAN ASSOCIATION). 
 
HARB, Mustafa Habib (Arabic: مصطفى حبيب حرب) (a.k.a. HARB, Mostafa Habib; a.k.a. HARB, Mustapha), Haruf, al-Nabatiyah, Lebanon; DOB 06 Aug 1973; POB Haruf, Lebanon; nationality Lebanon; Additional Sanctions Information - Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Gender Male (individual) [SDGT] (Linked To: AL-QARD AL-HASSAN ASSOCIATION). 
 
OTHMAN, Hasan Chehadeh (Arabic: حسن شحاده عثمان) (a.k.a. OTHMAN, Hassan Shehadeh; a.k.a. "UTHMAN, Hassan"), Baalbak, Lebanon; DOB 29 Jun 1979; nationality Lebanon; Additional Sanctions Information - Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Gender Male; National ID No. 3571577 (Lebanon) (individual) [SDGT] (Linked To: AL-QARD AL-HASSAN ASSOCIATION). 
 
SUBAYTI, Wahid Mahmud (Arabic: وحيد محمود سبيتي) (a.k.a. SBAYTI, Wahid; a.k.a. SBEITY, Waheed Mahmoud), Kfar Sir, Nabatieh, Lebanon; DOB 23 Feb 1961; nationality Lebanon; Additional Sanctions Information - Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Gender Male; National ID No. 473548 (Lebanon) (individual) [SDGT] (Linked To: AL-QARD AL-HASSAN ASSOCIATION). 
 
YAZBECK, Ahmad Mohamad (Arabic: احمد محمد يزبك), Kared Al Hassan Building, 1st Floor, Haret Hreik, Baabda, Lebanon; Nahala Baalbek, Baalbek and Hermel, Lebanon; DOB 01 Dec 1971; nationality Lebanon; Additional Sanctions Information - Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Gender Male (individual) [SDGT] (Linked To: AL-QARD AL-HASSAN ASSOCIATION). 

to its counter terrorism sanctions program.

It also removed the following Syria and Syrian Foreign Sanctions Evaders (FSE) designations – these are all SDN listings:

JAMI JAMI (a.k.a. JAMA' JAMA'; a.k.a. JAMEA, Jamea Kamil; a.k.a. JAM'I JAM'I); DOB 16 Jun 1954; POB Jablah, Zama, Syria; Brigadier General (individual) [SYRIA]. 
 
JAMEA, Jamea Kamil (a.k.a. JAMA' JAMA'; a.k.a. JAM'I JAM'I; a.k.a. JAMI JAMI); DOB 16 Jun 1954; POB Jablah, Zama, Syria; Brigadier General (individual) [SYRIA]. 
 
JAMA' JAMA' (a.k.a. JAMEA, Jamea Kamil; a.k.a. JAM'I JAM'I; a.k.a. JAMI JAMI); DOB 16 Jun 1954; POB Jablah, Zama, Syria; Brigadier General (individual) [SYRIA]. 
 
JAM'I JAM'I (a.k.a. JAMA' JAMA'; a.k.a. JAMEA, Jamea Kamil; a.k.a. JAMI JAMI); DOB 16 Jun 1954; POB Jablah, Zama, Syria; Brigadier General (individual) [SYRIA]. 
 
STAROIL B.V. (a.k.a. STAROIL S.A.), Wilhelminastraat 43 A, Haarlem 2011 VK, Netherlands; 30 A Rte de Chene, Geneva 1208, Switzerland; Registration ID 819860578 (Netherlands); V.A.T. Number NL 819860578B01 (Netherlands); Commercial Registry Number 34311024 (Netherlands) [SYRIA] [FSE-SY]. 
 
STAROIL S.A. (a.k.a. STAROIL B.V.), Wilhelminastraat 43 A, Haarlem 2011 VK, Netherlands; 30 A Rte de Chene, Geneva 1208, Switzerland; Registration ID 819860578 (Netherlands); V.A.T. Number NL 819860578B01 (Netherlands); Commercial Registry Number 34311024 (Netherlands) [SYRIA] [FSE-SY]. 
 
HOLLEBRAND, Alexander (a.k.a. HOLLEBRAND, Sander); DOB 20 Dec 1954; POB Netherlands (individual) [SYRIA] [FSE-SY]. 
 
HOLLEBRAND, Sander (a.k.a. HOLLEBRAND, Alexander); DOB 20 Dec 1954; POB Netherlands (individual) [SYRIA] [FSE-SY]. 
 
VAN MAZIJK, Paul; DOB 24 Jan 1958; Passport NSK7K05F4 (Netherlands) (individual) [SYRIA] [FSE-SY].

And the following Ukraine-related listing was updated:

PAVLENKO, Vladimir Nikolaevich (a.k.a. PAVLENKO, Volodymyr Mykolaiovych), Ukraine; Gender Male; Minister of State Security of the so-called Donetsk People's Republic (individual) [UKRAINE-EO13660] (Linked To: DONETSK PEOPLE'S REPUBLIC). -to- PAVLENKO, Vladimir Nikolaevich (Cyrillic: ПАВЛЕНКО, Владимир Николаевич) (a.k.a. PAVLENKO, Vladimir Viktorovich (Cyrillic: ПАВЛЕНКО, Владимир Викторович); a.k.a. PAVLENKO, Volodymyr Mykolaiovych; a.k.a. PAVLENKO, Volodymyr Viktorovich (Cyrillic: ПАВЛЕНКО, Володимир Вікторович)), Donetsk, Donetsk Oblast, Ukraine; DOB 14 Apr 1962; Gender Male; Minister of State Security of the so-called Donetsk People's Republic (individual) [UKRAINE-EO13660] (Linked To: DONETSK PEOPLE'S REPUBLIC). 

And the corresponding removals (and a few more) were made from the Foreign Sanctions Evaders (FSE) List:

STAROIL B.V. (a.k.a. STAROIL S.A.), Wilhelminastraat 43 A, Haarlem 2011 VK, Netherlands; 30 A Rte de Chene, Geneva 1208, Switzerland; Registration ID 819860578 (Netherlands); V.A.T. Number NL 819860578B01 (Netherlands); Commercial Registry Number 34311024 (Netherlands) [SYRIA] [FSE-SY]. 
 
STAROIL S.A. (a.k.a. STAROIL B.V.), Wilhelminastraat 43 A, Haarlem 2011 VK, Netherlands; 30 A Rte de Chene, Geneva 1208, Switzerland; Registration ID 819860578 (Netherlands); V.A.T. Number NL 819860578B01 (Netherlands); Commercial Registry Number 34311024 (Netherlands) [SYRIA] [FSE-SY]. 
 
HOLLEBRAND, Alexander (a.k.a. HOLLEBRAND, Sander); DOB 20 Dec 1954; POB Netherlands (individual) [SYRIA] [FSE-SY]. 
 
HOLLEBRAND, Sander (a.k.a. HOLLEBRAND, Alexander); DOB 20 Dec 1954; POB Netherlands (individual) [SYRIA] [FSE-SY]. 
 
VAN MAZIJK, Paul; DOB 24 Jan 1958; Passport NSK7K05F4 (Netherlands) (individual) [SYRIA] [FSE-SY].

And Treasury issued a press release about the new designations:

Links:

OFAC Notice

Treasury Press Release

Swiss officials updated the following individual designation under the Syrian sanctions program:

SSID: 200-11857 Name: Nizar Al-Assad
Sex: M DOB: a) 2 Mar 1948 b) 23 Mar 1948 c) Mar 1948 Good quality a.k.a.: al-Asad (Assad, AsadAsad, Assaad, Asaad, Al-Assaad) Nationality: a) Syrian Arab Republic b) Lebanon c) Canada Identification document: a) Passport No. 011090258, Syrian Arab Republic b) Passport No. RL0003434, Lebanon c) Passport No. AG629220, Canada Justification: a) Leading Syrian businessperson with close ties to the regime. Cousin of Bashar al-Assad, and associatedAssociated with the Assad and Makhlouf families. b) As such, he has been participating in, benefittingbenefiting from or otherwise supporting the Syrian regime. c) Leading oil investorinvestor, founder and previously head of the ‘Nizar Oilfield Supplies’Lead Contracting & Trading Ltd company. Relation: Cousin of Bashar Al- Assad (SSID 200-11614) Modifications: Amended on 6 Nov 2013, 19 Jan 2016, 12 Jun 2018, 13 Aug 2019, 1 Oct 2019, 26 Jun 2020, 21 May 2021

Links:

FINMA Notice

Data files of updates – PDF, XML

Link:

EU Notice