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OFAC Humanitarian Aid Fact Sheet: Syria

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Syria

OFAC’s Syria sanctions are designed to deter Bashar al-Assad, his cronies, foreign enablers, and the Government of Syria from accessing the international financial system and global supply chain. In addition, there are many illicit actors that operate in Syria, such as those related to Specially Designated Global Terrorists, Iran, or Russia, which may trigger additional sanctions prohibitions. OFAC remains committed to ensuring that these sanctions do not limit the ability of civilians located in Syria to receive humanitarian support from the international community. Such support may include providing items to the civilians of Syria, to include testing kits, respiratory devices, personal protective equipment, and medicine used in the prevention, diagnosis, treatment, and recovery from COVID-19. The United States government aims to work closely with the international organizations and humanitarian assistance community to address any obstacles.

General Licenses (GLs) and Specific Licensing: The following are GLs within the Syrian Sanctions Regulations (SySR) issued by OFAC related to humanitarian assistance and trade with Syria. Similarly, the exemptions below are also captured in title LXXI of the National Defense Authorization Act for Fiscal Year 2020, titled the “Caesar Syria Civilian Protection Act of 2019,” which codifies the GL in § 542.516 of the SySR (discussed below) that authorizes certain services in support of non-governmental organizations (NGO), and includes a humanitarian waiver.

• § 542.510 of the SySR authorizes certain exports or reexports to Syria of items licensed or otherwise authorized by the Department of Commerce (Commerce) and certain related services. This GL also authorizes certain services that are ordinarily incident to the exportation or reexportation of items to Syria and certain other services to install, repair, or replace such items, provided the export of such items is licensed or otherwise authorized by Commerce. Additionally, export of U.S. origin food and most medicines to Syria is not prohibited and does not require a Commerce or OFAC license (see Syria FAQ 229).

• § 542.512 of the SySR generally authorizes, subject to certain limitations, non- commercial personal remittances to or from Syria. OFAC also authorizes U.S. depository institutions, including banks and U.S.-registered money transmitters, to process noncommercial, personal remittances to or from Syria, or for or on behalf of an individual ordinarily resident in Syria, provided the funds transfer is not by, to, or through the Government of Syria or any person designated or otherwise blocked by OFAC.

• § 542.513 of the SySR authorizes activities of certain international organizations.

Subject to certain narrow limitations, the GL authorizes transactions and activities that are for the conduct of the official business of the United Nations, including its specialized agencies, programmes, funds, and related organizations by employees, contractors, or grantees of those organizations.

• § 542.516 of the SySR authorizes, subject to certain limitations, NGOs to provide certain services in support of, and certain U.S. financial institutions to process transfers of funds in support of, the following not-for-profit activities in Syria:

o Humanitarian projects that meet basic human needs; o Democracy-building;

o Projects supporting education;

o Non-commercial development projects directly benefitting the Syrian people; and

o Activities to support the preservation and protection of cultural heritage sites.

• § 542.525 of the SySR authorizes the exportation, reexportation, sale, or supply, directly

or indirectly, from the United States or by a U.S. person, wherever located, to Syria, including the Government of Syria, of services that are ordinarily incident to the exportation or reexportation to Syria, including to the Government of Syria, of non-U.S.- origin food, medicine, and medical devices that would be designated as EAR99 under the Export Administration Regulations (EAR) if it were subject to the EAR.

• § 542.532 of the SySR authorizes the provision on nonscheduled emergency medical services.

• Specific Licensing: For transactions not otherwise authorized by OFAC general licenses, OFAC considers specific license requests on a case-by-case basis and prioritizes license applications, compliance questions, and other requests related to humanitarian support for the Syrian people.


Get your terms straight, folks!

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From OFAC:

Guidance to Address Illicit Shipping and Sanctions Evasion Practices


The U.S. Departments of State and Treasury, and the U.S. Coast Guard, issued a global advisory to alert the maritime industry, and those active in the energy and metals sectors, to deceptive shipping practices used to evade sanctions, with a focus on Iran, North Korea, and Syria.  The advisory includes a detailed set of best practices for private industry to consider adopting to mitigate exposure to sanctions risk. 
The advisory updates and expands upon previous advisories issued by the U.S. government. It is intended to provide actors that utilize the maritime industry for trade with information on and tools to counter current and emerging trends in sanctions evasion related to shipping and associated services.  The advisory highlights common deceptive shipping practices used with respect to countries like Iran, North Korea, and Syria.

From the State Department:

The U.S. Department of State, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), and the U.S. Coast Guard issued a global advisory to alert the maritime industry, and those active in the energy and metals sectors to deceptive shipping practices used to evade sanctions, with a focus on Iran, North Korea, and Syria.  The advisory includes a detailed set of best practices for private industry to consider adopting to mitigate exposure to sanctions risk.  The deceptive shipping practices discussed in this report may create significant sanctions risk for individuals and entities involved in these industries.

The advisory updates and expands upon previous advisories issued by the U.S. government. It is intended to provide actors that utilize the maritime industry for trade with information on and tools to counter current and emerging trends in sanctions evasion related to shipping and associated services.  The advisory highlights common deceptive shipping practices used with respect to countries like Iran, North Korea, and Syria.

The advisory also includes best practices for different sectors of the maritime and energy industries, including global commodity traders, maritime insurers, financial institutions, ship owners and flag registries, and others, to assist in their due diligence and mitigation of sanctions risk.  Additionally, the advisory provides information about U.S. and United Nations sanctions relevant to the maritime industry, including a non-exhaustive list of activities for which persons could be sanctioned by the U.S. government.  The United States remains committed to disrupting shipping activities by malign actors worldwide—including sanctions evasion and smuggling—which may facilitate criminal activity and threatens international peace and security.

In the OFAC world, “advisory” and “guidance” mean very different things. “Guidance” generally tells you how you are expected to interpret various aspects of regulation – for example, the 50 Percent Rule is guidance. “Advisory” is different – it’s an information document that instructs on a particular area of interest and provides areas of particular concern in the hope that firms will take unspecified action (but some action) to try to address the problem. It is not as prescriptive as “guidance.”

The OFAC notice and the State Department media note both include the following:

The advisory includes a detailed set of best practices for private industry to consider adopting to mitigate exposure to sanctions risk. 

So, definitely, take the advisory to heart – but treat it as an advisory, not guidance. There’s no reason to run around with your hair on fire…

I’ll put up a separate post on the actual advisory…

Links:

OFAC Notice

State Department Media Note

Sanctions Advisory

EU extends Syria sanctions for another year

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Syria: Sanctions against the regime extended by one year

The Council today extended EU restrictive measures against the Syrian regime for one additional year, until 1 June 2021. In line with the EU strategy on Syria, the EU decided to maintain its restrictive measures against the Syrian regime and its supporters, as the repressionof the civilian population continues.

The Syrian people have had to draw on extraordinary reserves of resilience in the course of the conflict. The EU’s sanctions target those responsible for their suffering, members of the Syrian regime, their supporters and businesspersons who finance it and benefit from the war economy. The EU is determined to continue its support to the Syrian people and remains committed to use every tool at its disposal to push for a political solution to the conflict that would benefit all Syrians and put an end to the ongoing repression.

EU High Representative for Foreign Affairs and Security Policy Josep Borrell

The Council also removed from the list two persons and one company which halted their sanctionable behaviour, as well as two deceased persons. The list now includes 273 personstargeted by both an assets freeze and a travel ban, and 70 entities subject to an assets freeze.

Sanctions currently in place against Syria were introduced in 2011, in response to the violent repression by the Syrian regime of its civilian population. They also  target companies and business people benefitting from their ties with the regime and the war economy. Restrictive measures also include a ban on the import of oil, restrictions on certain investments, a freeze of the assets of the Syrian central bank held in the EU, and export restrictions on equipment and technology that might be used for internal repression, as well as on equipment and technology for the monitoring or interception of internet or telephone communications.

As part of the EU’s targeted approach to the use of sanctions, Syria sanctions are designed to avoid impeding the supply of humanitarian assistance. Consequently, the export of food, medicines or medical equipment are not subject to EU sanctions, and a number of specific exceptions are foreseen for humanitarian purposes.  

Background

The EU keeps developments in the Syrian conflict under constant review and can always decide to renew sanctions and amend the list of targeted entities or persons.

The EU remains committed to finding a lasting and credible political solution to the conflict in Syria on the basis of the UN Security Council resolution 2254 and of the 2012 Geneva Communiqué.

Link:

EU Notice

EU, OFSI remove 4 (really 5) from Syria sanctions

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Today, UK regulators removed the following 3 persons:

1. HAYKAL, Maen Rizk Allah
a.k.a: RIZKALLAH, Heikal, Bin Nationality: Syrian Position: Secondary Shareholder of Exceed Development and Investment Company Other Information: Leading businessperson operating in Syria, who holds a 33 % stake in Exceed Development and Investment, which has entered into a USD 17,7 million joint venture for the construction of Marota City, a regime-backed luxury residential and commercial development. Through the participation in the Marota City development, Maen Rizk Allah Haykal benefits from and/or supports the Syrian regime. Listed on: 22/01/2019 Last Updated: 22/01/2019 01/06/2020 Group ID: 13762.
2. JAMEA, Jamea
Title: Brigadier-General a.k.a: (1) JAME’, Jame’ (2) JAMI, Jami (3) JAMI’, Jami’ Position: Branch Chief for Syrian Military Intelligence (SMI) in Dayr az-Zor. Listed on: 24/08/2011 Last Updated: 31/05/2013 01/06/2020 Group ID: 12043.
3. KADDOUR, Hayan
DOB: (1) 14/07/1970. (2) 24/07/1970. POB: Damascus, Syria a.k.a: (1) NAZEM, Hayyan, Kaddour, bin, Mohammed (2) QADDOUR, Hayan, Mohammad, Nazem Nationality: (1) Syrian (2) Swiss Passport Details: X4662433 (place of issue: Switzerland), N 004599905 (place of issue: Syrian Arab Republic) Position: Primary Shareholder of Exceed Development and Investment Company Other Information: Leading businessperson operating in Syria, who holds a 67 % stake in Exceed Development and Investment, which has entered into a USD 17,7 million joint venture for the construction of Marota City, a regime-backed luxury residential and commercial development. Through his participation in the Marota City development, Hayan Mohammad Nazem Qaddour benefits from and/or supports the Syrian regime. Listed on: 22/01/2019 Last Updated: 22/05/2019 01/06/2020 Group ID: 13761.

and an entity:

1. DEVELOPERS PRIVATE JOINT STOCK COMPANY
a.k.a: Developers Private JSC Address: Damascus, Syria. Other Information: Developers Private Joint Stock Company is a USD 17,7 million joint venture between Damascus Cham Holdings and Exceed Development and Investment. Through its participation in the regime-backed luxury development Marota City, Developers Private Joint Stock Company supports and/or benefits from the Syrian regime. Listed on: 22/01/2019 Last Updated: 22/01/2019 01/06/2020 Group ID: 13768.

from its Syria sanctions program, as per Council Implementing Regulation (EU) 2020/716.

Additionally, the following listing:

1. SOLEIMANI, Qasem
Title: Major General DOB: 11/03/1957. POB: Qom, Iran a.k.a: (1) SALIMANI, Qasem (2) SOLAIMANI, Qasem (3) SOLEIMANY, Qasim (4) SOLEMANI,
Qasem (5) SOLEYMANI, Ghasem (6) SOLEYMANI, Qasem (7) SULAIMANI,
Qasem (8) SULAYMAN, Qasem (9) SULAYMAN, Qasmi (10) SULEMANI,
Qasem Nationality: Iranian (Iranian citizenship) Passport Details: 008827 issued in Iran Position: Commander of Iranian Revolutionary Guard Corps, IRGC – Qods Other Information: (Deceased). Both UK listing and EU listing under Terrorism and Terrorist Financing. EU listing under Syria. Promoted to Major General, retaining his position as Commander of Qods Force. UN listing under Iran (nuc prol). Male. UN Ref IRi.039. Also known as Haj Qasem, Haji Qassem and Sarder Soleimani. Listed on: 24/03/2007 Last Updated: 20/01/2020 01/06/2020 Group ID: 9062

was updated to remove its designation under the Syria program. However, he remains sanctioned under the Iran (Nuclear Proliferation) program instituted by the United Nations.

One editorial note: is it just me, or is it weird that OFSI updates the “Last Updated” date for removed listings? Assuming you remove this from your screening software, what is the purpose of updating this? I guess if you leave these in your system… but why?

Links:

OFSI Notice

Council Implementing Regulation (EU) 2020/716

June 4, 2020: EU, OFSI amend 335 Syria sanctions listings

June 4, 2020: About 8 months later, new Syria sanctions regulations.

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Publication of Syria-related Sanctions Regulations

 
The Office of Foreign Assets Control (OFAC) is issuing regulations to implement Executive Order 13894 of October 14, 2019 (“Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria”).  These regulations are currently available for public inspection with the Federal Register and will take effect upon publication in the Federal Register on June 5, 2020.  OFAC intends to supplement these regulations with a more comprehensive set of regulations, which may include additional interpretive and definitional guidance, general licenses, and statements of licensing policy.  

Links:

OFAC Notice

New Syria Sanctions Regulations Federal Register Notice

State’s out of the gate first: Syria Caesar Act designations…

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More than six years ago, the brave photographer known as Caesar shocked the world by smuggling out of Syria the photographic proof that the Assad regime was torturing and executing many thousands of Syrians in the regime’s prisons.  This act of bravery is the inspiration behind the Caesar Syria Civilian Protection Act (the Caesar Act), signed into law by President Trump 180 days ago, under which the U.S. Congress authorized severe economic sanctions to promote accountability for brutal acts against the Syrian people by the Assad regime and its foreign enablers.  As of today, the sanctions provisions of the Caesar Act are fully in effect.  Anyone doing business with the Assad regime, no matter where in the world they are, is potentially exposed to travel restrictions and financial sanctions.

Today, the Treasury Department and State Department are releasing 39 designations under the Caesar Act and Executive Order 13894 as the beginning of what will be a sustained campaign of economic and political pressure to deny the Assad regime revenue and support it uses to wage war and commit mass atrocities against the Syrian people.

We are designating the architect of this suffering Bashar Al-Assad and his wife Asma al-Assad pursuant to E.O. 13894 Section 2(a)(i)(A) and Section 2(a)(ii), respectively, as well as  funder of these atrocities Mohammed Hamsho and Iranian militia Fatemiyoun Division pursuant to E.O. 13894 2(a)(i)(D).  We are further designating Maher al-Assad, along with his Fourth Division of the Syrian Arab Army and its leadership Ghassan Ali Bilal and Samer al-Dana pursuant to E.O. 13894 Section 2(a)(i)(A).  Lastly, we are designating Bushra al-Assad, Manal al-Assad, Ahmad Sabir Hamsho, Amr Hamsho, Ali Hamsho, Rania al-Dabbas, and Sumaia Hamcho under E.O. 13894 Section 2(a)(ii).

We will continue this campaign in the coming weeks and months to target individuals and businesses that support the Assad regime and obstruct a peaceful, political resolution of the conflict as called for by UNSCR 2254.  We anticipate many  more sanctions and we will not stop until Assad and his regime stop their needless, brutal war against the Syrian people and the Syrian government agrees to a political solution to the conflict as called for by UNSCR 2254.   We will undertake our campaign of economic and political pressure in full cooperation with other like-minded nations, especially our European partners, who only three weeks ago renewed their own sanctions against the Assad regime for precisely the same reasons.

Many of the dozens of people and companies the U.S. government is sanctioning today have played a key role in obstructing a peaceful political solution to the conflict.  Others have aided and financed the Assad regime’s atrocities against the Syrian people while enriching themselves and their families.  I will make special note of the designation for the first time of Asma al-Assad, the wife of Bashar al-Assad, who with the support of her husband and members of her Akhras family has become one of Syria’s most notorious war profiteers.  Now anyone doing business with any of these persons or entities is at risk of sanctions.

For more than nine years, the Assad regime has waged a bloody war against the Syrian people and committed innumerable atrocities, some of which rise to the level of war crimes and crimes against humanity, including killings, torture, enforced disappearances, and the use of chemical weapons.  Since the conflict began, more than half a million Syrians have died and eleven million people – half of Syria’s pre-war population – have been displaced.  Bashar al-Assad and his regime squander tens of millions of dollars each month to fund their needless war, destroying homes, schools, shops, and public markets.  Their destructive war has exacerbated the humanitarian crisis, prevented life-saving assistance from reaching those in need, and brought misery to the Syrian people.

The United States remains committed to working with the UN and international partners to bring life-saving assistance to the Syrian people who continue to suffer at the hands of the Assad regime.  We are the single largest humanitarian donor for the Syrian people and since the start of the conflict, have provided over $10.6 billion in humanitarian assistance and over $1.6 billion in non-humanitarian and stabilization assistance across Syria, even in areas under Assad’s control.  The Caesar Act and other U.S. Syria sanctions do not target humanitarian assistance for the Syrian people or hinder our stabilization activities in northeast Syria.   We will continue our humanitarian assistance through our various international and Syrian partners, even in areas under regime control.

It is time for Assad’s needless, brutal war to end.  Today, the Assad regime and those who support it have a simple choice: take irreversible steps toward a lasting political solution to the Syrian conflict in line with UNSCR 2254 or face ever new tranches of crippling sanctions.

When OFAC comes out with its designations, I’ll post them, too…

Link:

State Department Press Release

And a Fact Sheet, too…

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  • The President signed into law the “Caesar Syria Civilian Protection Act of 2019” (the Caesar Act) on December 20, 2019.

  • Named after the Syrian photographer who bravely shared with the world thousands of photographs documenting torture in Assad’s prisons, the Caesar Act provides the U.S. government a powerful way to promote accountability for the regime’s atrocities.

  • Our sanctions under the Caesar Act and Executive Order 13894 are not intended to harm the Syrian people, but rather to promote accountability for the Assad regime’s violence and destruction that has killed hundreds of thousands of civilians; subjected thousands of Syrians to arbitrary detention, the majority of whom remain missing, and many of whom are exposed to torture and sexual violence; and devastated the country’s civilian infrastructure, including homes, hospitals, and marketplaces, resulting in the displacement of over half the population.  This Act is meant to send a clear signal that no foreign business should enter into business with or otherwise enrich such a regime.

  • Executive Order 13894 includes menu-based sanctions including travel restrictions to the United States and isolation from the United States’ financial system for foreign persons who engage in or finance the obstruction, prevention, or disruption of a ceasefire or political solution to the conflict in Syria and members of their family, among other actions.

  • Mandatory sanctions under the Caesar Act target foreign persons who facilitate the Assad regime’s acquisition of goods, services, or technologies that support the regime’s military activities as well as its aviation and oil and gas production industries.

  • The Caesar Act also mandates sanctions on those profiting off the Syrian conflict by engaging in reconstruction activities.

  • The United States will actively impose and enforce the full range of U.S. sanctions under EO 13894 and our other sanction authorities, including the Caesar Act, against the Assad regime and its enablers in order to exert maximum pressure on the Syrian regime towards full implementation of the political process.

  • The sanctions imposed on June 17 are the start of the Administration’s efforts to implement the Caesar Act.  We will continue to target those who enable the Assad regime to carry out atrocities and to needlessly prolong the Syrian conflict.

  • The Administration is committed to answering the calls of the Syrian people for a lasting political solution to the Syrian conflict in line with UNSCR 2254.

  • The Assad regime has a choice: take irreversible steps towards a peaceful resolution of the nearly decade-long conflict or face further crippling sanctions.

  • The United States Syria sanctions do not generally sanction bona fide humanitarian assistance or activity.  The implementation of the Caesar Act continues that practice, including by codifying the  general license under the Syrian Sanctions Regulations for NGO humanitarian activity.  Rather, the United States’ Syria and Syria-related sanctions prohibitions are designed to deter Bashar al-Assad and his regime from abusing the international financial system and global supply chain to continue brutalizing the Syrian people.  We also intend to prevent the Assad regime and its associates from profiteering from the war that the regime itself has thrust upon the Syrian people.

  • Since the beginning of our sanctions against the Assad regime, we have provided exemptions for humanitarian aid in all areas of Syria.   In fact, there are U.S. government programs working with NGOs to deliver medicines and foodstuff to nearly all parts of Syria, including regime-held areas.

  • We remain committed to ensuring that civilians living in Syria are able to receive humanitarian support from the international community.

Link:

Caesar Act Fact Sheet


Hail Caesar! OFAC adds & amends Syria sanctions designations

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In conjunction with the State Department’s pronouncements earlier today, OFAC added the following persons:

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]. 
 
AL-ASSAD, Bushra (Arabic: بشرى الاسد) (a.k.a. SHAWKAT, Bushra), Dubai, United Arab Emirates; DOB 24 Oct 1960; POB Egypt; nationality Syria; Gender Female (individual) [SYRIA-EO13894]. 
 
AL-ASSAD, Manal (Arabic: منال الاسد) (a.k.a. AL-AHMAD, Manal; a.k.a. AL-AKHRAZ, Manal; a.k.a. JAADAN, Manal), Damascus, Syria; DOB 02 Feb 1970; POB Damascus, Syria; nationality Syria; Gender Female (individual) [SYRIA-EO13894]. 
 
ALDABBAS, Rania (a.k.a. AL DABAS, Rania Raslan; a.k.a. AL DABBAS, Rania Raslan (Arabic: رانية رسلان الدباس); a.k.a. DABAS, Rania Raslan; a.k.a. DABBAS, Rania Raslan), Damascus, Syria; Dubai, United Arab Emirates; DOB 02 Jun 1974; POB Damascus, Syria; nationality Syria; Gender Female; Passport N003000785 (Syria) (individual) [SYRIA-EO13894]. 
 
AL-DANA, Samer (Arabic: سامر الدانا), Damascus, Syria; DOB 01 May 1968; POB Damascus, Syria; nationality Syria; Gender Male; Passport 3463215 (Syria); Brigadier General; Commander of the 41st Brigade of the FOURTH DIVISION of the Syrian Arab Army (individual) [SYRIA-EO13894]. 
 
AL-OLABI, Adel Anwar (Arabic: عادل انور العلبي) (a.k.a. AL-OLABI, Adil Anwar; a.k.a. AL-‘ULABI, ‘Adel Anwar; a.k.a. EL-OULABI, Adel Anouar), Damascus, Syria; DOB 1976; POB Damascus, Syria; nationality Syria; Gender Male (individual) [SYRIA]. 
 
AL-ZUBAIDI, Khaled (Arabic: خالد الزبيدي) (a.k.a. AL-ZUBAIDI, Khaled Bassam; a.k.a. AL-ZUBAIDI, Mohammed Khaled Bassam; a.k.a. ZUBAIDI, Mohammed Khaled; a.k.a. ZUBEDI, Khalid), Syria; Canada; DOB 10 Apr 1976; nationality Syria; alt. nationality Canada; Gender Male; Passport N 006540969 (Syria); alt. Passport HC246053 (Canada) (individual) [SYRIA] [SYRIA-CAESAR]. 
 
BILAL, Ghassan Ali (Arabic: غسان علي بلال) (a.k.a. BELAL, Ghassan), Damascus, Syria; DOB 1966; nationality Syria; Gender Male; Commander of the 555th Regiment and Director of the Security Bureau of the Fourth Division of the Syrian Arab Army (individual) [SYRIA-EO13894]. 
 
HAMCHO, Sumaia Saber (Arabic: سعمية صابر حمشو) (a.k.a. HAMSHO, Somaya Saber), Doha, Qatar; DOB 16 Apr 1965; POB Damascus, Syria; nationality Syria; alt. nationality Qatar; Gender Female; Passport 01175686 (Qatar) (individual) [SYRIA-EO13894]. 
 
HAMSHO, Ahmad Sabir Mohammed (a.k.a. HAMCHO, Ahmad Saber (Arabic: احمد صابر حمشو); a.k.a. HAMCHO, Ahmad Saber Mohamad; a.k.a. HAMSHOU, Ahmed Saber Mohammed), Damascus, Syria; Dubai, United Arab Emirates; London, United Kingdom; DOB 25 Nov 1992; POB Damascus, Syria; nationality Syria; Gender Male; Passport N005364444 (Syria) (individual) [SYRIA-EO13894]. 
 
HAMSHO, Ali Muhammad (Arabic: علي محمد حمشو) (a.k.a. HAMCHO, Ali; a.k.a. HAMCHO, Ali Mohamad; a.k.a. HAMSHOU, Ali Mohammed), Damascus, Syria; Paris, France; DOB 03 Nov 1998; POB Damascus, Syria; nationality Syria; Gender Male; Passport N005361042 (Syria) (individual) [SYRIA-EO13894]. 
 
HAMSHO, Amr Mohamed (a.k.a. HAMCHO, Amre (Arabic: عمرو حمشو); a.k.a. HAMCHO, Amre Mohamad; a.k.a. HAMSHO, Amrou Mohammed; a.k.a. HAMSHOU, Amrou Mohammed), Damascus, Syria; DOB 07 Mar 1995; POB Damascus, Syria; nationality Syria; Gender Male; Passport N005361043 (Syria) (individual) [SYRIA-EO13894]. 
 
JAMALEDDINE, Nazir Ahmad Mohammed (Arabic: نذير احمد محمد جمال الدين) (a.k.a. JAMAL EDDIN, Mohammed Nazer; a.k.a. JAMAL EDDINE, Natheer Ahmed Mohammed; a.k.a. JAMAL EDDINE, Nathier Ahmed Mohammed), Damascus, Syria; DOB 02 Jan 1962; POB Damascus, Syria; nationality Syria; Gender Male; Passport N011612445 (Syria); alt. Passport 002-17-L022286 (Syria); National ID No. 010-30208342 (Syria) (individual) [SYRIA] [SYRIA-CAESAR]. 
 
KALAI, Nader (Arabic: نادر قلعي) (a.k.a. AL KALAI, Nadir; a.k.a. KALAI, Nader Mohamad; a.k.a. KALAI, Nader Mohammed Wajieh; a.k.a. KALEI, Nader; a.k.a. QALAI, Nader; a.k.a. QALEI, Nader), 871 Young Avenue, Halifax, Nova Scotia B3H 2V8, Canada; Ain El Mraisse, Beirut, Lebanon; Saifi Street, Jemayzeh, Beirut, Lebanon; Capsurville, Dekwaneh, El Metn Jemayzeh, Beirut, Lebanon; Ghrayeb Bldg, Sami Soloh St, Badaro, Beirut, Lebanon; DOB 09 Jul 1965; POB Damascus, Syria; nationality Syria; alt. nationality Canada; Gender Male; Passport N 010170320(Syria); National ID No. 010-40036453 (Syria); alt. National ID No. 34191608 (Canada) (individual) [SYRIA] [SYRIA-CAESAR]. 

and entities:

AL-AMAR ONE-PERSON LLC (Arabic: شركة العمار ذات الشخص الواحد المحدودة المسؤولية) (a.k.a. AL-AMMAR LLC ONE PERSON COMPANY; a.k.a. “AL-AMMAR”), Rural Damascus, Syria; Organization Established Date 18 Jan 2017; Organization Type: Real estate activities with own or leased property [SYRIA] [SYRIA-CAESAR]. 
 
APEX DEVELOPMENT AND PROJECTS LLC (Arabic: شركة القمة للتطویر والمشاریع المحدودة المسؤولیة) (a.k.a. AL ‘QIMA DEVELOPMENT AND PROJECTS LLC; a.k.a. SUMMIT DEVELOPMENT AND PROJECTS LLC), Rural Damascus, Syria; Organization Established Date 17 Jan 2018; Organization Type: Real estate activities with own or leased property [SYRIA] [SYRIA-CAESAR]. 
 
ART HOUSE GMBH, Sieveringerstrasse 164, Vienna 1190, Austria; National ID No. FN292891 y (Austria) [SYRIA] (Linked To: CASTLE HOLDING GMBH). 
 
BUNYAN DAMASCUS PRIVATE JOINT STOCK COMPANY (Arabic: شركة بنيان دمشق المساهمة المغلفة الخاصة) (a.k.a. BUNYAN DAMASCUS), Marota City, Eastern Villas, Mazeh, Damascus 096311, Syria; Organization Established Date Apr 2018; Organization Type: Construction of buildings; alt. Organization Type: Real estate activities with own or leased property [SYRIA] (Linked To: DAMASCUS CHAM HOLDING COMPANY). 
 
CASTLE HOLDING GMBH (a.k.a. “CASTLE HOLDING”; a.k.a. “CASTLE HOLDING INVESTMENT”; a.k.a. “CASTLE INVEST”; a.k.a. “CASTLE INVEST HOLDING”), Sieveringerstrasse 164, Vienna 1190, Austria; National ID No. FN292092Y (Austria) [SYRIA] (Linked To: KALAI, Nader). 
 
CASTLE INVESTMENT HOLDING (Arabic: شركة كاسل إنفست هولدنغ ش.م.ل.) (a.k.a. CASTLE INVEST HOLDING COMPANY SAL; a.k.a. CASTLE INVEST HOLDING SAL; a.k.a. CASTLE INVESTMENT HOLDING PRIVATE JSC; a.k.a. “CASTLE HOLDINGS”), West Mazzeh, Damascus, Syria; First Floor, Sami Saleh Avenue, Beirut, Lebanon; Registration Number 1900127 (Lebanon) [SYRIA] (Linked To: KALAI, Nader). 
 
DAMASCUS CHAM FOR MANAGEMENT LLC (Arabic: دمشق الشام الادارة) (a.k.a. DAMASCUS CHAM MANAGEMENT CO. LTD.; a.k.a. DAMASCUS CHAM MANAGEMENT ONE-PERSON CO. LTD.), Marota City, Eastern Villas, Mazeh, Damascus 096311, Syria; Organization Established Date 2018; Organization Type: Real estate activities with own or leased property [SYRIA] (Linked To: DAMASCUS CHAM HOLDING COMPANY). 
 
DAMASCUS CHAM HOLDING COMPANY (Arabic: شركة دمشق الشام القابضة) (a.k.a. DAMASCUS CHAM HOLDING PRIVATE JSC; a.k.a. DAMASCUS CHAM PRIVATE JOINT STOCK COMPANY), Marota City, Eastern Villas, Mazeh, Damascus 096311, Syria; Organization Established Date 17 Dec 2016; Business Registration Number 17951 (Syria) [SYRIA]. 
 
EBLA HOTEL (Arabic: فندق إيبلا) (a.k.a. EBLA HOTEL AND OMAYAD PALACE FOR CONFERENCES), Airport Road – 4th Bridge, Damascus, Syria; P.O. Box 6416, Damascus, Syria; Organization Established Date 1989; Organization Type: Short term accommodation activities [SYRIA]. 
 
FOURTH DIVISION OF THE SYRIAN ARAB ARMY (Arabic: الفرقة الرابعة في الجيش العربي السوري), Syria [SYRIA-EO13894]. 
 
GRAND TOWN TOURIST CITY (Arabic: غراند تاون المدينة السياحة) (a.k.a. GRAND TOWN; a.k.a. GRAND TOWN TOURISM PROJECT (Arabic: مشروع غراند تاون السياحي); a.k.a. ZK GRAND TOWN), Airport Road, after the Fourth Bridge, Damascus, Syria; Website http://www.facebook.com/ZKGrandTown/; Organization Established Date 2017; Organization Type: Real estate activities on a fee or contract basis [SYRIA]. 
 
KALAI INDUSTRIES (Arabic: قلعي للصناعات) (a.k.a. KALAI INDUSTRIES MANAGEMENT; a.k.a. MOHAMMED KALAI), Dara Autostrad (Amman Highway), Kessweh, 500m after the Katakir Bridge, Damascus, Syria; Organization Established Date 1990; Registration Number 38372 (Syria) [SYRIA] (Linked To: KALAI, Nader). 
 
MIRZA COMPANY (Arabic: شركة ميرزا) (a.k.a. MIRZA CO.), Marota City, Eastern Villas, Mazeh, Damascus 096311, Syria; Organization Established Date 14 Jan 2018; Organization Type: Construction of buildings; alt. Organization Type: Real estate activities with own or leased property [SYRIA] (Linked To: DAMASCUS CHAM HOLDING COMPANY). 
 
RAMAK DEVELOPMENT AND HUMANITARIAN PROJECTS LLC (Arabic: راماك للمشاريع التنموية و الانسانية) (a.k.a. RAMAK COMPANY FOR DEVELOPMENT AND HUMANITARIAN PROJECTS LLC), Rural Damascus, Syria; Organization Established Date 08 Aug 2011; Organization Type: Real estate activities with own or leased property; alt. Organization Type: Construction of buildings [SYRIA] [SYRIA-CAESAR]. 
 
RAWAFED DAMASCUS PRIVATE JOINT STOCK COMPANY (Arabic: شركة روافد دمشق المساهمة المغفلة الخاصة) (a.k.a. RAWAFED DAMASCUS INVESTMENTS COMPANY; a.k.a. RAWAFED DAMASCUS PRIVATE JSC; a.k.a. RAWAFID DAMASCUS PRIVATE JOINT STOCK COMPANY; a.k.a. TRIBUTARIES DAMASCUS PRIVATE JSC), Marota City, Damascus, Syria; Organization Established Date 08 Apr 2018; Organization Type: Real estate activities with own or leased property; alt. Organization Type: Construction of buildings [SYRIA]. 
 
TAMAYOZ LLC (Arabic: شركة تميز المحدودة المسؤولية) (a.k.a. EXCELLENCE LIMITED LIABILITY COMPANY), Damascus, Syria; Organization Type: Real estate activities with own or leased property [SYRIA] [SYRIA-CAESAR]. 
 
TELEFOCUS CONSULTANTS INC (a.k.a. TELEFOCUS CONSULTANTS INC CANADA), 871 Young Ave, Halifax, Nova Scotia B3H 2V8, Canada; Commercial Registry Number 3234614 (Canada) [SYRIA] (Linked To: KALAI, Nader). 
 
TELEFOCUS SAL OFFSHORE (Arabic: تيليفوكوس ش.م.ل.(اوف شور)), Mir Bachir St, Riad El Solh, Beirut, Lebanon; 7th Floor-Riad-Solh Lazarieh Tower, Beirut, Lebanon; 1470 Bachoura – Azaria Building – 7th Floor, Beirut, Lebanon; Registration Number 1802940 (Lebanon) [SYRIA] (Linked To: KALAI, Nader). 
 
TIMEET TRADING LLC (Arabic: شركة التيميت للتجارة المحدودة المسؤولية) (a.k.a. ULTIMATE TRADING LLC), Rural Damascus, Syria; Organization Type: Real estate activities with own or leased property [SYRIA] [SYRIA-CAESAR]. 
 
WINGS PRIVATE JSC (Arabic: شركة الاجنحة المساهمة المغفلة الخاصة) (a.k.a. WINGS PRIVATE JOINT STOCK COMPANY), Rural Damascus, Syria; Organization Type: Real estate activities with own or leased property [SYRIA] [SYRIA-CAESAR]. 
 
ZUBAIDI AND QALEI LLC (Arabic: شركة زبيدي وقلعي المحدودة المسؤولية) (a.k.a. ZUBEDI & KALAI; a.k.a. ZUBEDI AND KALAI; a.k.a. “ZK HOLDING”), Airport Road, Damascus, Syria; P.O. Box 6416, Damascus, Syria; Organization Type: Real estate activities on a fee or contract basis [SYRIA]. 

under its Syria sanctions program. You’ll note some of these, but not all, include the new SYRIA-CAESAR program tag. Personally, I wish they would separate these out for clarity.

Oh, and OFAC changed the following listings:

AL-ASAD, Mahir (a.k.a. ASSAD, Mahar; a.k.a. ASSAD, Maher); DOB 1968; Lieutenant Colonel; Position: Brigade Commander in the Syrian Army’s 4th Armored Division (individual) [SYRIA]. -to- AL-ASSAD, Maher (Arabic: ماهر الأسد) (a.k.a. AL-ASAD, Mahir; a.k.a. ASSAD, Mahar; a.k.a. ASSAD, Maher), Damascus, Syria; DOB 08 Dec 1967; POB Damascus, Syria; nationality Syria; Gender Male; Diplomatic Passport 4138 (Syria); Major General; Commander of the Syrian Army’s 4th Armored Division (individual) [SYRIA] [SYRIA-EO13894]. 
 
AL-ASSAD, Bashar (a.k.a. AL ASSAD, Bashar Hafez; a.k.a. AL-ASAD, Bashar; a.k.a. ASSAD, Bashar); DOB 11 Sep 1965; POB Damascus, Syria; President of the Syrian Arab Republic (individual) [SYRIA]. -to- AL-ASSAD, Bashar (Arabic: بشار الأسد) (a.k.a. AL ASSAD, Bashar Hafez; a.k.a. AL-ASAD, Bashar; a.k.a. ASSAD, Bashar), Damascus, Syria; DOB 11 Sep 1965; POB Damascus, Syria; nationality Syria; Gender Male; President of the Syrian Arab Republic (individual) [SYRIA] [SYRIA-EO13894]. 
 
FATEMIYOUN DIVISION (a.k.a. FATEMIOUN BRIGADE; a.k.a. FATEMIOUN MILITARY DIVISION; a.k.a. FATEMIYOUN; a.k.a. FATEMIYOUN BATTALION; a.k.a. FATEMIYOUN FORCE; a.k.a. FATEMIYYUN; a.k.a. LIWA FATEMIYOUN), Syria; Iran; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IRGC] [IFSR] [IRAN-HR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE). -to- FATEMIYOUN DIVISION (Arabic: لواء فاطميون) (a.k.a. FATEMIOUN BRIGADE; a.k.a. FATEMIOUN MILITARY DIVISION; a.k.a. FATEMIYOUN; a.k.a. FATEMIYOUN BATTALION; a.k.a. FATEMIYOUN FORCE; a.k.a. FATEMIYYUN; a.k.a. LIWA FATEMIYOUN), Syria; Iran; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IRGC] [IFSR] [IRAN-HR] [SYRIA-EO13894] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE). 
 
HAMSHO, Muhammad (a.k.a. HAMCHO, Mohamed; a.k.a. HAMSHO, Mohammad; a.k.a. HAMSHO, Mohammed Saber; a.k.a. HAMSHOU, Mohammed; a.k.a. HAMSHU, Muhammad Sabir); DOB 20 May 1966; POB Damascus, Syria; nationality Syria; Passport 002954347(individual) [SYRIA]. -to- HAMSHO, Muhammad (a.k.a. HAMCHO, Mohamed; a.k.a. HAMSHO, Mohammad; a.k.a. HAMSHO, Mohammed Saber; a.k.a. HAMSHOU, Mohammed; a.k.a. HAMSHU, Muhammad Sabir), Syria; DOB 20 May 1966; POB Damascus, Syria; nationality Syria; Gender Male; Passport 002954347 (Syria) (individual) [SYRIA] [SYRIA-EO13894]. 

Note that some of these are also under the Executive Order 13894 program tag, which was also mentioned by State today.

Link:

OFAC Notice

Random Thought of the Day: Caesar Syria sanctions

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So, sanctions are not intended to be imposed in perpetuity – if a party stops the activities that resulted in their being sanctioned, they should be able to get de-listed.

Well… so, if you’re a firm that provides military aircraft to the Government of Syria, or a militia, etc…. and then the Syrian civil war finally ends with Assad prevailing over the remaining forces opposing his rule. So, you’re no longing providing the aircraft because there is no longer a need…

Can you get delisted? You didn’t really change your actions through a change of heart – but you’re no longer doing the thing that got you sanctioned.

Imagine the calculus for a firm who believes that Assad will win the war in the next year or so. Do you take your chances, given that you can say “it was only once – I’m not doing it anymore”?

SECO amends a raft of Syrian designations

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Earlier today, Swiss regulators issued a massive set of amendments to Syrian sanctions designations. The PDF runs 64 pages, and the amendments don’t have any easily-apparent pattern…

Links:

FINMA Notice

Data files of updates – PDF, XML

Random thought of the Day: Executive Order 13894

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The bulk of OFAC’s June 17th designations bore the program tag [SYRIA-E.O.13894]. This Executive Order is the only one issued under the “Syria-related” sanctions program. This Executive Order allows the designation of people belonging to the Turkish government, any subdivision of it, or anyone determined to be:


(A) to be responsible for or complicit in, or to have directly or indirectly engaged in, or attempted to engage in, any of the following in or in relation to Syria:

(1) actions or policies that further threaten the peace, security, stability, or territorial integrity of Syria; or

(2) the commission of serious human rights abuse;

Clearly, the designations on the 17th were for these reasons, as they also occurred on the same day a number of designations were made under the new Caesar Syria Civilian Protection Act authorities.

So, why are there two Syria sanctions program? Why not just roll the two together, especially since the stand-off with Syria over its incursion into Northern Syria (where they threatened the Kurdish population) is over with?

Just askin’…

OFAC Enforcement Action: Amazon.com

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The settlement: $134,523

The base penalty: $134,523…. but the statutory maximum was $1,038,206,212

What were the actual violations?

From on or about November 15, 2011, to on or about October 18, 2018, persons located in Crimea, Iran, and Syria placed orders or otherwise conducted business on Amazon’s websites for consumer and retail goods and services where the transaction details demonstrated that the goods or services would be provided to persons in Crimea, Iran, or Syria. Amazon also accepted and processed orders on its websites for persons located in or employed by the foreign missions of Cuba, Iran, North Korea, Sudan, and Syria.

Additionally, Amazon accepted and processed orders from persons listed on OFAC’s List of Specially Designated Nationals and Blocked Persons (the “SDN List”) who were blocked pursuant to the Narcotics Trafficking Sanctions Regulations, the Weapons of Mass Destruction Proliferators Sanctions Regulations, the Transnational Criminal Organizations Sanctions Regulations, the Democratic Republic of the Congo Sanctions Regulations, the Venezuela Sanctions Regulations, the Zimbabwe Sanctions Regulations, the Global Terrorism Sanctions Regulations, and the Foreign Narcotics Kingpin Sanctions Regulations. Overall, the apparent violations consisted primarily of transactions involving low-value retail goods and services for which the total transaction value of the apparent violations was approximately $269,000.

Why did they occur?

These apparent violations occurred primarily because Amazon’s automated sanctions screening processes failed to fully analyze all transaction and customer data relevant to compliance with OFAC’s sanctions regulations. In some instances, orders specifically referenced a sanctioned jurisdiction, a city within a sanctioned jurisdiction, or a common alternative spelling of a sanctioned jurisdiction, yet Amazon’s screening processes did not flag the transactions for review. For example, Amazon’s screening processes did not flag orders with address fields containing an address in “Yalta, Krimea” for the term “Yalta,” a city in Crimea, nor for the variation of the spelling of Crimea. In another example, Amazon failed to interdict or otherwise flag orders shipped to the Embassy of Iran located in third countries. Moreover, in several hundred instances, Amazon’s automated sanctions screening processes failed to flag the correctly spelled names and addresses of persons on OFAC’s SDN List.

But, wait, there’s more:

Finally, Amazon disclosed to OFAC that it failed to report 362 transactions involving Crimea that it had conducted pursuant to General License No. 5, “Authorizing Certain Activities Prohibited by Executive Order 13685 of December 19, 2014 Necessary to Wind Down Operations Involving the Crimea Region of Ukraine” (GL 5), which authorized certain transactions prohibited by E.O. 13685 through February 1, 2015. The terms of GL 5 included a requirement that transactions authorized by GL 5 be reported within 10 days after the wind-down activities concluded. As stated in § 501.801(a) of the Reporting, Procedure and Penalties Regulations, 31 C.F.R. Part 501, “Persons availing themselves of certain general licenses may be required to file reports and statements in accordance with the instructions specified in those licenses. Failure to file timely all required information in such reports or statements may nullify the authorization otherwise provided by the general license and result in apparent violations of the applicable prohibitions that may be subject to OFAC enforcement action.” Amazon previously identified and reported to OFAC 245 transactions involving Crimea undertaken pursuant to GL 5 on February 13, 2015 (within the required reporting period), but did not report an additional 362 such transactions until well after the required reporting period had expired. Because of this reporting failure, the authorization in GL 5 is nullified with respect to those 362 transactions.

The aggravating factors:

(1) Amazon failed to exercise due caution or care when it implemented sanctions screening processes that failed to properly flag transactions involving blocked persons and sanctioned jurisdictions. In particular, Amazon did not properly review or assess addresses, customer names, or common variations of such data as part of its sanctions screening.

(2) While the apparent violations primarily involved the provision of low-value retail and consumer goods and services, some of the apparent violations related to Amazon’s processing of orders for personal security products on behalf of persons located at the Iranian embassies in Tokyo, Japan, and in Brussels, Belgium.

(3) Amazon provides consumer goods and services via its e-commerce websites and processes billions of global transactions annually, and is one of the largest and most commercially sophisticated companies in the world.

The mitigating factors:

(1) Amazon had 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.

(2) Amazon voluntarily self-disclosed the apparent violations to OFAC, cooperated with OFAC’s investigation by providing data analysis of the apparent violations and submitting detailed information in a well-organized manner, and entered into tolling agreements with OFAC. In addition, Amazon conducted an internal investigation without receiving an administrative subpoena and identified and disclosed the circumstances of the transactions that led to the apparent violations.

(3) Upon discovering the apparent violations, Amazon undertook significant remedial measures to address its sanctions screening deficiencies and has also agreed as part of its settlement with OFAC to undertake various additional sanctions compliance commitments designed to minimize the risk of recurrence of similar conduct in the future. Such measures include:

 Investing substantial resources to improve Amazon’s overall sanctions compliance program, including by actively engaging senior management on its compliance improvements, adding significant headcount to its compliance teams, and increasing the frequency of its sanctions compliance reviews;

 Employing internal and third-party sources to conduct a thorough review of Amazon’s sanctions compliance program and its automated screening systems in order to address the screening failures that gave rise to the apparent violations. In particular, Amazon is incorporating additional automated preventative screening controls designed to scale and operate effectively for its overall retail business;

 Developing internally custom screening lists to minimize the risk of processing transactions that raise sanctions compliance concerns;

 Enhancing its sanctioned jurisdiction Internet Protocol (IP) blocking controls and implementing automated processes to update continually its mapping of IP ranges associated with sanctioned jurisdictions;

 Bolstering its compliance training programs by providing training tailored to the roles of specific teams and specialized ad-hoc training to personnel responsible for sanctions and export control compliance; and

 Expanding the use of specific export control and sanctions provisions and the language of those provisions in its agreements.

Our takeaway? In this case, there are two:

This case demonstrates the importance of implementing and maintaining effective, risk-based sanctions compliance controls, including sanctions screening measures appropriate for e- commerce and other internet-based businesses that operate on a global scale. Such large and sophisticated businesses should implement and employ compliance tools and programs that are commensurate with the speed and scale of their business operations. In particular, global companies that rely heavily on automated sanctions screening processes should take reasonable, risk-based steps to ensure that their processes are appropriately configured to screen relevant customer information and to capture data quality issues, such as common misspellings. Routine testing of these processes to ensure effectiveness and identify deficiencies may also be appropriate. Moreover, companies that learn of a weakness in their internal compliance controls may benefit by taking immediate and effective action, to the extent possible, to identify and implement compensating controls until the root cause of the weakness can be determined and remediated.

This case also demonstrates the importance of compliance with all aspects of the terms of OFAC’s general licenses, including the timely fulfillment of any reporting obligations pursuant to those licenses.

How about Mr. Watchlist’s takeaway? I have a few:

  • Undoubtedly, each individual retail violation is a pretty petty thing to issue a penalty over. However, because this stretched on for 6-7 years, and involved so many sanctions programs, and so many transactions, I think OFAC needed to flag this. Had it be 10-20 items over the course of a year, maybe this gets a Finding of Violation.
  • It’s shocking that a firm of Amazon’s size and commercial sophistication would be so sloppy in doing the paperwork – it’s a real “unforced error.”
  • It’s also pretty shocking that Amazon wasn’t searching for geographic references like “Iran.” To be honest, I don’t think it’s reasonable to go out and identify every overseas diplomatic facility (and, logically, where every staffer lives). And I highly doubt that the Embassy made those purchases, but staff at the embassy did. But, certainly, you should be stopping all references to names of countries and major cities. That being said, it can be pretty challenging – if Liberia had had comprehensive sanctions (when you need to look for geographic references, since the restrictions are not just on specific parties), some of the cities there are also really common Western ones – like Greenville and Glendale. Especially when you consider Amazon’s size of operations.
  • I think the final settlement was fair-ish. At the end of the day, Amazon had bad software and/or regulatory data – it wasn’t a process of procedure failure. Perhaps one thing OFAC could have suggested is that technology purchases need to have active input from Compliance. A good compliance officer would have noticed that geographic references were not in the installed solution – and could have teased that “Yalta, Krimea” case out in user acceptance testing.

One more thing: look at the categories attached to this post. That gives you a list of all the sanctions programs they ended up violating (not that their conduct was in any way, shape or form related to specific sanctions programs).

Link:

Enforcement Information

More oopsies: OFSI amends 1, removes 1 Syria designation

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Today, UK regulators removed:

1. AL-FURAYJ, Fahd Jasim

DOB: 01/01/1950. POB: Hama, Syria a.k.a: (1) AL-FREIJ, Jasem (2) AL-FREIJ, Jasim (3) AL- FREIJ, Jassimm (4) AL-FURAYJ, Fahd, Jassem (5) AL-FURAYJ, Jasem (6) AL-FURAYJ, Jasim (7) AL-FURAYJ, Jassim Other Information: Former Minister of Defence and Deputy Commander in Chief of the Syrian Armed Forces. Listed on: 16/10/2012 Last Updated: 27/02/2018 10/07/2020 Group ID: 12763.

from their Syria sanctions program and amended:

1. AL-JARROUCHEH, Ahmed

DOB: –/–/1957. a.k.a: (1) AL-JAROUCHA, Ahmad (2) AL-JAROUCHA, Ahmed (3) AL- JAROUCHAH, Ahmad (4) AL-JAROUCHAH, Ahmed (5) AL-JAROUCHEH, Ahmad (6) AL- JAROUCHEH, Ahmed (7) AL-JAROUSHA, Ahmad (8) AL-JAROUSHA, Ahmed (9) AL- JAROUSHEH, Ahmad (10) AL-JAROUSHEH, Ahmed (11) AL-JARROUCHEH, Ahmad Other Information: Gender: male. Former Head of the foreign branch of General Intelligence (Branch 279). Responsible for General Intelligence arrangements in Syrian embassies. Listed on: 24/07/2012 Last Updated: 04/06/2020 10/07/2020 Group ID: 12724.

under the same program. The delisting was done, per Council Implementing Regulation (EU) No 2016/1735 – and the amendment as per Council Implementing Regulation (EU) 2020/716.

This notice was also marked “Correction”…

Links:

OFSI Notice

Council Implementing Regulation (EU) No 2016/1735

Council Implementing Regulation (EU) 2020/716

Suspicions confirmed…

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OFSI corrects six listings

OFSI has removed 5 individuals and amended 1 on the consolidated list.

North Korea (DPRK) regime:
The entry for Ri Pyong Chol (Group ID: 13546) has been removed.

Democratic Republic of the Congo regime:
The entries for Robert Kibelisa (Group ID: 13437) and Lambert Mende (Group ID: 13463) have been removed.

Libya regime:
The entry for Mas’ud Abdulhafiz (Group ID: 11641) has been removed.

Syria regime:
The entry for Fahd Jasim al-Furayj (Group ID: 12763) has been removed. The entry for Ahmed al-Jarroucheh (Group ID: 12724) has been updated. The individual is on the consolidated list and remains subject to an asset freeze.

OFSI’s consolidated list of asset freeze targets has been updated to reflect this change.


Syria-go-round: Syria & Syria-related additions & removal

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Today, OFAC added the following persons:

AL-ASSAD, Hafez (Arabic: حافظ الاسد) (a.k.a. ASSAD, Hafez), Syria; DOB 04 Dec 2001; POB Damascus, Syria; nationality Syria; Gender Male (individual) [SYRIA-EO13894] (Linked To: AL-ASSAD, Bashar). 
 
AL-ASSAD, Karam (Arabic: كرام الاسد) (a.k.a. ASSAD, Karam), Syria; DOB 1978; POB Qardaha, Syria; nationality Syria; Gender Male (individual) [SYRIA-EO13894] (Linked To: AL-ASSAD, Zuhair Tawfik). 
 
AL-ASSAD, Zuhair Tawfik (Arabic: زهير توفيق الاسد) (a.k.a. AL-ASSAD, Zuhair Tawfiq; a.k.a. AL-ASSAD, Zuheir Tawfiq; a.k.a. ASSAD, Zuhair), Syria; DOB 1958; POB Qardaha, Syria; nationality Syria; Gender Male (individual) [SYRIA-EO13894]. 
 
AL-QATTAN, Wassim Anwar (Arabic: وسيم انوار القطان) (a.k.a. AL-KATAN, Wassim Anouar; a.k.a. AL-KATTAN, Waseem; a.k.a. AL-KATTAN, Wasseem; a.k.a. AL-QATAN, Waseem; a.k.a. QATTAN, Waseem; a.k.a. QATTAN, Wasim), Damascus, Syria; DOB 04 Mar 1976; nationality Syria; Gender Male (individual) [SYRIA] [SYRIA-CAESAR]. 

and entities:

ADAM TRADING AND INVESTMENT LLC (Arabic: شركة ادم التجارة و الاستثمار), Damascus, Syria; Organization Established Date 25 Feb 2018; Organization Type: Real estate activities on a fee or contract basis [SYRIA] [SYRIA-CAESAR] (Linked To: AL-QATTAN, Wassim Anwar). 
 
AL-JALAA HOTEL (Arabic: فندق الجلاء) (a.k.a. AL-JALA’ HOTEL; a.k.a. AL-JALAA), Mazzeh Motorway, Damascus, Syria; Organization Type: Short term accommodation activities [SYRIA]. 
 
FIRST DIVISION OF THE SYRIAN ARAB ARMY (Arabic: الفرقة الأولى الجيش العربي السوري) (a.k.a. “1ST ARMORED DIVISION”; a.k.a. “FIRST ARMORED DIVISION” (Arabic: “الفرقة الأولى المدرعة“)), Syria [SYRIA-EO13894]. 
 
INTERSECTION LLC (Arabic: شركة نقطة تقاطع), Rural Damascus, Syria; Organization Established Date 11 Mar 2018; Organization Type: Construction of buildings [SYRIA] [SYRIA-CAESAR] (Linked To: AL-QATTAN, Wassim Anwar). 
 
LAROSA FURNITURE (Arabic: مفروشات لاروسا) (a.k.a. LAROSA FURNISHING), Damascus, Syria; Organization Type: Manufacture of furniture [SYRIA] (Linked To: AL-QATTAN, Wassim Anwar). 
 
MASSA PLAZA MALL (a.k.a. AL-MALIKI MALL (Arabic: مول المالكي); a.k.a. MALKI MALL), Malki District, Damascus, Syria [SYRIA]. 
 
MURUJ CHAM INVESTMENT AND TOURISM GROUP (a.k.a. MUROOJ AL-CHAM INVESTMENT AND TOURISM COMPANY (Arabic: شركة مروج الشام الاستثمار و السياحة); a.k.a. MUROOJ AL-CHAM INVESTMENT AND TOURISM GROUP), 1149 Main Street, Al-Saboura, Damascus, Syria; Organization Established Date 23 Jun 2015; Organization Type: Real estate activities on a fee or contract basis; alt. Organization Type: Construction of buildings [SYRIA] [SYRIA-CAESAR] (Linked To: AL-QATTAN, Wassim Anwar). 
 
QASIOUN MALL (Arabic: مول قاسيون) (a.k.a. QASIYUN MALL; a.k.a. QASSIOUN SHOPPING MALL), Barzeh District, Damascus, Syria [SYRIA]. 
 
WASSIM KATTAN LLC (a.k.a. “TWA LLC” (Arabic: “شركة تي دبلايو ا“); a.k.a. “WK LLC” (Arabic: “شركة دبليو ك“)), Rural Damascus, Syria; Organization Established Date 04 Jul 2019; Organization Type: Sale of motor vehicle parts and accessories [SYRIA] (Linked To: AL-QATTAN, Wassim Anwar). 
 
YALBAGHA COMPLEX (Arabic: مجمع يلبغا) (a.k.a. YALBUGHA COMPLEX; a.k.a. YALBUGHA REAL ESTATE COMPOUND), Damascus, Syria; Organization Type: Short term accommodation activities [SYRIA]. 

to the Syria or Syria-related sanctions program, and made the following de-listings (one guy, two listings):

HAMCHO, Sumaia Saber (Arabic: سعمية صابر حمشو) (a.k.a. HAMSHO, Somaya Saber), Doha, Qatar; DOB 16 Apr 1965; POB Damascus, Syria; nationality Syria; alt. nationality Qatar; Gender Female; Passport 01175686 (Qatar) (individual) [SYRIA-EO13894]. 
 
HAMSHO, Somaya Saber (a.k.a. HAMCHO, Sumaia Saber (Arabic: سعمية صابر حمشو)), Doha, Qatar; DOB 16 Apr 1965; POB Damascus, Syria; nationality Syria; alt. nationality Qatar; Gender Female; Passport 01175686 (Qatar) (individual) [SYRIA-EO13894]. 

and here’s State’s explanation:

Today, the State Department and Treasury Department continued the United States’ sanctions campaign against the Assad regime by releasing 14 new designations under the Caesar Syria Civilian Protection Act and other authorities. This campaign began last month with the first round of Caesar Act designations.

We have named today’s tranche of designations the Hama and Maarat Al-Numan sanctions. These names are meant to memorialize the victims of two of the Assad regime’s most notorious atrocities, both of which occurred in this week in 2011 and 2019.  Nine years ago, Bashar al-Assad’s troops carried out a brutal siege of the city of Hama, killing scores of peaceful protesters in a shocking sign of what was to come.  One year ago, the Assad regime and its allies bombed a busy marketplace in Maarat Al-Numan, killing 42 innocent Syrians.

The Assad regime’s military has become a symbol of brutality, repression, and corruption. They have killed hundreds of thousands of civilians, detained and tortured peaceful protesters, and destroyed schools, hospitals, and markets without regard to human life. We are designating Zuhair Tawfiq al-Assad and the First Division of the Syrian Arab Army pursuant to E.O. 13894 Section 2(a)(i)(A), in addition to Zuhair Tawfiq al Assad’s adult son, Karam al-Assad, under Section 2(a)(ii).  Among today’s actions, we are also designating Bashar al-Assad’s adult son Hafez al-Assad pursuant to E.O. 13894 Section 2(a)(ii).   We will continue to hold Bashar al-Assad and his regime accountable for their atrocities, while keeping the memory of their victims alive.

It is time for Assad’s needless, brutal war to end.  This, above all, is what our sanctions campaign is meant to bring about. A political solution under UNSCR 2254 is the only credible path to the peace the Syrian people deserve.  The Caesar Act and other U.S. Syria sanctions are not intended to harm the Syrian people and do not target humanitarian assistance or hinder our stabilization activities in northeast Syria.  We will continue our humanitarian assistance through our international and Syrian partners, even in areas under the Assad regime’s control.  The United States has contributed more than $11.3 billion in humanitarian assistance since the start of the conflict and will continue to do so.

There must be accountability and justice for the victims of Hama, Maarat al-Numan, and of the Assad regime’s other war crimes and crimes against humanity. The Assad regime and those who support it have a simple choice: take irreversible steps toward a lasting political solution to end the Syrian conflict as called for by UNSCR 2254 or face new tranches of crippling sanctions.

Links:

OFAC Notice

State Department Press Release

New OFAC Syria & Syria-related designations

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Today, OFAC added the following persons:

AL SHIBL, Luna (Arabic: لونا الشبل) (a.k.a. AL CHEBEL, Luna; a.k.a. AL CHEBIL, Luna; a.k.a. AL SHEBEL, Luna; a.k.a. AL SHEBIL, Luna; a.k.a. AL SHIBIL, Luna; a.k.a. ALSHEBEL, Luna; a.k.a. AL-SHIBL, Luna; a.k.a. CHEBEL, Luna; a.k.a. SHIBL, Luna), Damascus, Syria; DOB 01 Sep 1975; POB Suweida, Syria; alt. POB Damascus, Syria; nationality Syria; Gender Female (individual) [SYRIA]. 
 
DALAH, Ghaith (Arabic: غايث دلا) (a.k.a. DALA, Ghayth; a.k.a. DALA, Ghiath; a.k.a. DALLAH, Gaith), Damascus, Syria; DOB 31 Jul 1971; POB Beit Yashout, Syria; nationality Syria; Gender Male (individual) [SYRIA-EO13894]. 
 
IBRAHIM, Yasser Hussein (Arabic: يسار حسين ابراهيم) (a.k.a. IBRAHIM, Yasar; a.k.a. IBRAHIM, Yassar), Syria; DOB 09 Apr 1983; POB Damascus, Syria; nationality Syria; Gender Male (individual) [SYRIA-EO13894]. 
 
ISMAIL, Samer (Arabic: سامر اسماعيل), Homs, Syria; DOB 25 Oct 1980; nationality Syria; Gender Male (individual) [SYRIA-EO13894]. 
 
SAATI BIN MOHAMAD NAWZAD, Mohamad Ammar (Arabic: محمد عمار ساعاتي بن محمد نوزاد) (a.k.a. AL-SAATI, Ammar (Arabic: عمار الساعاتي); a.k.a. SAATI, Amar; a.k.a. SAATI, Ammar; a.k.a. SAATI, Mohamed Ammar; a.k.a. SA’ATI, Mohamed Ammar; a.k.a. SA’ATI, Mohammad Ammar; a.k.a. SAATI, Mohammad Ammar (Arabic: محمد عمار ساعاتي); a.k.a. SA’ATI, Mohammed Ammar; a.k.a. SAATI, Mohammed Ammar; a.k.a. SAATI, Muhammed Ammar), Syria; DOB 01 Jan 1967; POB Damascus, Syria; nationality Syria; Gender Male (individual) [SYRIA]. 
 
SAQR, Fadi (Arabic: فادي صقر) (a.k.a. SAKIR, Fadi; a.k.a. SAKR, Fady; a.k.a. SAQER, Fadi; a.k.a. SAQIR, Fadi), Damascus, Syria; DOB 1975; POB Jeblah, Syria; nationality Syria; Gender Male (individual) [SYRIA-EO13894]. 

under its Syria or Syria-related (SYRIA-E.O13894 program tag) sanctions programs.

I’m sure there will be a press release later.

Link:

OFAC Notice

Mike Pompeo Explains It All: Today’s Syria designations

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Tomorrow will mark the seventh anniversary of the Assad regime’s chemical weapons attack in Ghouta which killed over 1,400 Syrians. Today, in memory of the victims that brutality, the United States is announcing six sanctions against the Assad regime’s military, government, and financial supporters. As we continue to implement the goals of the Caesar Syria Civilian Protection Act, we reaffirm our commitment to not stand by idly while Assad prolongs this conflict and the suffering of the Syrian people. We will continue pressure against the Assad regime to compel it to end its attacks against the Syrian people.
We are imposing sanctions on Assad’s henchman, Yasser Ibrahim, under Executive Order 13894 section 2(a)(i)(D) for his efforts to prevent or obstruct a political solution to the Syrian conflict. Using his networks across the Middle East and beyond, Ibrahim has cut corrupt deals that enrich Assad, while Syrians are dying from a lack of food and medicine.
As part of today’s action, the Treasury Department is taking action against the Syrian presidential office and against the Syrian Ba’ath Party. Specifically, Treasury’s Office of Foreign Assets Control is designating, pursuant to Executive Order 13573, Luna Al Shibl, Assad’s presidential media advisor, and Mohamad Amar Saati, a senior Ba’ath party official who led an organization that facilitated the entry of university students into Assad-backed militias. They are among the many corrupt figures Assad has chosen as his advisors, not those focused on peacefully resolving Syria’s conflict.
Today we are also designating, pursuant to Executive Order 13894 section 2(a)(i)(A), leadership of several Syrian military units for their efforts to prevent a ceasefire in Syria. In the National Defense Forces, we are designating NDF commander Fadi Saqr. In the 4th Division, we are designating 42nd Brigade commander, Brigadier General Ghaith Dalah. Finally, in the Tiger Forces we are designating the Haider Regiment commander, Samer Ismail.
These senior officials lead the same Syrian military that has killed children with barrel bombs and used chemicals weapons against communities like Ghouta. They have shattered the social contract between citizens and the military sworn to protect them. Today’s sanctions reinforce our commitment to hold Assad’s generals and militia commanders accountable for their violations and abuses. We will aggressively pursue sanctions against other Syrian military commanders, as well as enforce existing U.S. sanctions against many current and retired commanders such as Lieutenant General Ali Ayoub, Major General Ali Mamluk, Brigadier General Bassam Al-Hassan, Major General Jamil Hassan, Major General Mohammad Dib Zaitoun, Brigadier General Suheil Hassan, Major General Rafiq Shahadah, and Major General Abd al-Fatah Qudsiyah. We will also support the sanctions our EU allies have levied against Assad’s military, including Major General Kifah Melhem, Brigadier General Nasser al-Ali, Major General Ghassan Ismail, Major General Hussam Luka, and militia commander Saqr Rustom. These brutal leaders of Assad’s war machine should have no role in Syria’s future.
While these Assad regime supporters prolong the brutal Syrian conflict, the United States and its international partners are standing by the Syrian people calling for peace. We support efforts to convene the UN-facilitated, Syrian-led Constitutional Committee and hope all participating recommit themselves to building a peaceful future for Syria. The only path to resolve this conflict is through the nationwide cease fire and political process outlined in United Nations Security Council Resolution 2254. The United States and its allies are united in continuing to apply pressure on Assad and his enablers until there is peaceful, political solution to the conflict. Assad and his foreign patrons know the clock is ticking for action. In the meantime, the United States will continue to impose costs on anyone, anywhere who obstructs a peaceful political solution to the Syrian conflict.

Link:

State Department Press Release

Where in the world is OFAC today? Syria and Cuba

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Today, OFAC added the following people under the Syria sanctions related to Executive Order 13894:

IBRAHIM, Nasreen Hussein (Arabic: نسرين حسين إبراهيم) (a.k.a. IBRAHIM, Nisrine; a.k.a. IBRAHIM, Nsrin; a.k.a. IBRAHIM, Nsrin Hussin), Damascus, Syria; DOB 13 Nov 1975; POB Latakia, Syria; nationality Syria; Gender Female; National ID No. 06110008173(Syria) (individual) [SYRIA-EO13894]. 
 
IBRAHIM, Rana Hussein (Arabic: رنا حسين ابراهيم) (a.k.a. IBRAHIM, Rana Hussin), Damascus, Syria; DOB 07 Oct 1994; POB Damascus, Syria; nationality Syria; Gender Female; National ID No. 06110065397 (Syria) (individual) [SYRIA-EO13894]. 
 
JEDID, Milad (Arabic: ميلاد جديد) (a.k.a. JADEED, Milad; a.k.a. JADID, Milad; a.k.a. JEDEED, Milad), Syria; DOB May 1963; POB Qardaha, Latakia, Syria; nationality Syria; Gender Male (individual) [SYRIA-EO13894]. 

as well as the following people:

BIN ALI, Khodr Taher (Arabic: خضر طاهر بن علي) (a.k.a. Al-Jaja; a.k.a. KHODR, Abou Ali; a.k.a. KHODR, Abu Ali (Arabic: ابو علي خضر); a.k.a. TAHER, Khader Ali; a.k.a. TAHER, Kheder Ali; a.k.a. TAHER, Khider Ali; a.k.a. TAHER, Khodr Ali (Arabic: خضر علي طاهر); a.k.a. “AL-KHUDUR, Khudhur Taher”; a.k.a. “JIJEH, Abu Ali”), Damascus, Syria; Tartous, Syria; DOB 1976; POB Safita, Tartous, Syria; nationality Syria; Gender Male (individual) [SYRIA]. 
KARFOUL, Hazem Younes (Arabic: حازم يونس قرفول) (a.k.a. KARFOUL, Hazem (Arabic: حازم قرفول); a.k.a. QARFOUL, Hazem Younes), Damascus, Syria; DOB 09 Jul 1976; POB Tartus, Syria; nationality Syria; Gender Male (individual) [SYRIA]. 
 
LOUKA, Husam Muhammad (Arabic: حسام محمد لوقا) (a.k.a. LOUCA, Housam; a.k.a. LOUCA, Houssam; a.k.a. LOUCA, Husam; a.k.a. LOUCA, Hussam; a.k.a. LOUKA, Hussam (Arabic: حسام لوقا); a.k.a. LUKA, Hussam; a.k.a. LUQA, Husam; a.k.a. LUQA, Hussam), Damascus, Syria; DOB 1964; POB Damascus, Syria; alt. POB Khanasser, Aleppo, Syria; nationality Syria; Gender Male (individual) [SYRIA]. 

and entities:

AL ALI AND AL HAMZA LLC (Arabic: شركة العلي والحمزة), Rural Damascus, Syria; Organization Established Date 15 Jan 2019; Organization Type: Wholesale of construction materials, hardware, plumbing and heating equipment and supplies [SYRIA] (Linked To: BIN ALI, Khodr Taher). 
 
CASTLE SECURITY AND PROTECTION LLC (a.k.a. AL-QALAA COMPANY FOR SECURITY SERVICES; a.k.a. AL-QALA’A FOR PROTECTION, GUARDING, AND SECURITY SERVICES (Arabic: شركة القلعة للحماية و الحراسة و الخدمات الامنية); a.k.a. C.S.P. CASTLE PROTECTION, GUARDING AND SECURITY SERVICES; a.k.a. CASTLE COMPANY FOR PROTECTION, GUARDING AND SECURITY SERVICES; a.k.a. CITADEL FOR PROTECTION, GUARD AND SECURITY SERVICES; a.k.a. “CASTLE SECURITY AND PROTECTION”), Opposite the gas station, enter hospital 601, Sheikh Saad, Mazzeh, West Villas, Damascus, Syria; Aleppo, Syria; Organization Type: Private security activities [SYRIA] (Linked To: BIN ALI, Khodr Taher). 
 
ELLA MEDIA SERVICES LLC (Arabic: شركة ايلا للخدمات الاعلامية), Damascus, Syria; Organization Established Date 07 Apr 2019; Organization Type: Advertising [SYRIA] (Linked To: BIN ALI, Khodr Taher). 
 
ELLA TOURISM COMPANY (Arabic: شركة ايلا للسياحة) (a.k.a. IYLA FOR TOURISM), Syria; Organization Established Date 16 Aug 2017; Organization Type: Tour operator activities [SYRIA] (Linked To: BIN ALI, Khodr Taher). 
 
EMMA LLC (Arabic: شركة ايما), Damascus, Syria; Organization Established Date 19 Jan 2017; Organization Type: Postal activities; alt. Organization Type: Other financial service activities, except insurance and pension funding activities, n.e.c.; Only locations in Syria [SYRIA] (Linked To: BIN ALI, Khodr Taher). 
 
EMMA TEL LLC (Arabic: ايماتيل) (a.k.a. EMATEL COMMUNICATIONS; a.k.a. EMATEL LLC; a.k.a. EMMATEL; a.k.a. IMATEL FOR COMMUNICATIONS (Arabic: شركة ايماتيل للاتصالات); a.k.a. “EMATEL”), Shaalan, Damascus, Syria; Mazzeh Highway, Damascus, Syria; Behind Revolution Street, al-Lahoudiyeh, Tartous, Syria; New Zahira Highway, Al Zahira, Damascus, Syria; Marjeh, Damascus, Syria; Daraa Highway, Town Center, Damascus, Syria; Eastern Qalamoun, Rural Damascus, Syria; Flowers Street, Tartous, Syria; The Main Circle, Civilization Street, Homs, Syria; Quwatli Street, Homs, Syria; Murabit, Hama, Syria; Al Jamelaiah, Aleppo, Syria; Baghdad Street, Latakia, Syria; Latakia, Syria; March 8th Street, Latakia, Syria; University Highway, Al-Zahira, Latakia, Syria; Amara Street, Jeblah, Syria; Daraa, Syria; Al-Qamashil, Northeastern Region, Syria; Al-Hasakah, Syria; Deir Ezzor, Syria; Organization Type: Wholesale of electronic and telecommunications equipment and parts [SYRIA] (Linked To: BIN ALI, Khodr Taher). 
 
EMMA TEL PLUS LLC (Arabic: شركة ايماتيل بلس) (a.k.a. IMATEL PLUS LLC), Damascus, Syria; Organization Established Date 17 Jan 2019; Organization Type: Wholesale of electronic and telecommunications equipment and parts [SYRIA] (Linked To: BIN ALI, Khodr Taher). 
 
GOLDEN STAR TRADING LLC (Arabic: شركة النجم الذهبي التجارية), Rural Damascus, Syria; Organization Established Date 23 Oct 2019; Organization Type: Wholesale of electronic and telecommunications equipment and parts [SYRIA] (Linked To: BIN ALI, Khodr Taher). 
 
JASMINE CONTRACTING COMPANY (Arabic: شركة الياسمين التعهدات) (a.k.a. AL-YASMEEEN CONTRACTING COMPANY; a.k.a. AL-YASMEEN FOR CONTRACTING; a.k.a. AL-YAZMEEN FOR CONTRACTING; a.k.a. YASMIN FOR CONTRACTING), Damascus, Syria; Organization Established Date 14 Dec 2017 [SYRIA] (Linked To: BIN ALI, Khodr Taher). 
 
SYRIAN COMPANY FOR METALS AND INVESTMENTS LLC (Arabic: شركة السورية للمعادن و الاستثمار), Damascus, Syria; Organization Established Date 22 Oct 2018; Organization Type: Wholesale of metals and metal ores [SYRIA] (Linked To: BIN ALI, Khodr Taher). 
 
SYRIAN HOTEL MANAGEMENT LLC (Arabic: الشركة السورية للادارة الفندقية), Damascus, Syria; Organization Established Date 02 May 2017; Organization Type: Short term accommodation activities [SYRIA] (Linked To: BIN ALI, Khodr Taher). 
 
SYRIAN MINISTRY OF TOURISM (Arabic: وزارة السياحة السورية), P.O. Box 6642, Victoria Street, Barada Bank, Damascus, Syria; Kwatli Street, Barada Bank, Damascus 96311, Syria; Website http://www.syriatourism.org; Organization Established Date 1972 [SYRIA]. 
 
SYRIAN TRANSPORT AND TOURISM COMPANY (Arabic: الشركة السورية للنقل و السياحة) (a.k.a. SYRIAN TRANSPORT AND TOURISM JSC), Al-Bahsa, Damascus, Syria; Organization Established Date 1952; Organization Type: Tour operator activities; alt. Organization Type: Short term accommodation activities [SYRIA] (Linked To: SYRIAN MINISTRY OF TOURISM). 

under the general Syria sanctions program.

Additionally, the following person was added to the Cuba sanctions program:

RODRIGUEZ LOPEZ-CALLEJA, Luis Alberto (Latin: RODRÍGUEZ LÓPEZ-CALLEJA, Luis Alberto) (a.k.a. RODRIGUEZ LOPEZ-CALLEJAS, Luis Alberto (Latin: RODRÍGUEZ LÓPEZ-CALLEJAS, Luis Alberto)), Calle 49 A Nro. 3626, Playa, Havana, Cuba; DOB 19 Jan 1960; POB Cuba; nationality Cuba; Gender Male; Passport A009956 (Cuba) issued 23 Jan 2017 expires 23 Jan 2029 (individual) [CUBA]. 

OFAC also issued a new General License for the Syria program “Authorizing Transactions and Activities Necessary for Wind Down of Transactions with Emma Tel LLC” through December 30th of this year. They also issued the following Frequently Asked Question:

841. What does Syria General License 20 authorize?

Answer

Syria General License (GL) 20 authorizes, subject to certain conditions, all transactions and activities prohibited by the Syrian Sanctions Regulations (SySR) that are ordinarily incident and necessary to the wind down of transactions involving, directly or indirectly, Emma Tel LLC or any entity in which Emma Tel LLC owns, directly or indirectly, a 50 percent or greater interest, through 12:01 a.m. eastern standard time, December 30, 2020.  Persons unable to wind down transactions prohibited by the SySR involving, directly or indirectly, Emma Tel LLC, or any entity in which Emma Tel LLC owns, directly or indirectly, a 50 percent or greater interest, before 12:01 a.m. eastern standard time, December 30, 2020, are encouraged to seek guidance from OFAC.  

For the duration of GL 20, non-U.S. persons may wind down transactions involving, directly or indirectly, Emma Tel LLC, or any entity in which Emma Tel LLC owns, directly or indirectly, a 50 percent or greater interest, without exposure to sanctions under the Caesar Syria Civilian Protection Act of 2019, provided that such wind down activity is consistent with GL 20.  While GL 20 is in effect, wind down transactions involving non-U.S. persons may be processed through the U.S. financial system or involve U.S. persons, as long as the transactions comply with the terms and conditions in GL 20.  Non-U.S. persons unable to wind down transactions involving, directly or indirectly, Emma Tel LLC or any entity in which Emma Tel LLC owns, directly or indirectly, a 50 percent or greater interest before 12:01 a.m. eastern standard time, December 30, 2020, are encouraged to seek guidance from OFAC.

And the Treasury Department issued the following press release:

PRESS RELEASES

Treasury Continues Targeting Facilitators of Assad Regime

Washington – Today, as part of the U.S. government’s continued effort to achieve a peaceful, political resolution of the Syrian conflict, the U.S. Department of the Treasury is taking action against key enablers of the Assad regime that are associated with the Fourth Division of the Syrian Arab Army, the Syrian General Intelligence Directorate, and the Central Bank of Syria. Specifically, Treasury’s Office of Foreign Assets Control (OFAC) added three individuals and 13 entities to the Specially Designated Nationals and Blocked Persons List, pursuant to Syria sanctions authorities. Treasury is sanctioning a prominent, regime-connected Syrian businessman, who serves as an intermediary for the Fourth Division of the Syrian Arab Army, and his network of businesses that generate revenue for the regime and its supporters. Additionally, today’s action includes the designations of two key Assad regime officials: the head of the Syrian General Intelligence Directorate and the Governor of the Central Bank of Syria.

“Those who continue to stand with the brutal regime of Bashar al-Assad further enable its corruption and human rights abuses,” said Secretary Steven T. Mnuchin. “As we mark three years since the regime’s slaughter of Syrian civilians in Armanaz, Syria, the United States will continue to employ all of its tools and authorities to target the finances of anyone who profits from or facilitates the Assad regime’s abuse of the Syrian people.”

Concurrent with the Treasury Department’s designations, the State Department took action against three Syrian persons pursuant to Section 2 of Executive Order (E.O.) 13894, “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria.”

KHODR TAHER BIN ALI AND HIS BUSINESS NETWORK

Khodr Taher Bin Ali (Taher) is a Syrian businessman who serves as a prominent local intermediary and contractor for the designated Fourth Division of the Syrian Arab Army (Fourth Division). The Fourth Division is an elite military unit, led by Maher al-Assad, the brother of Bashar al-Assad, that was founded to protect the regime from internal and external threats. On April 29, 2011, the President included Bashar al-Assad and Maher al-Assad in the Annex to E.O. 13572, Blocking Property of Certain Persons With Respect to Human Rights Abuses in Syria.” On January 12, 2017, OFAC identified the Syrian Arab Army as falling within the definition of the Government of Syria, as set forth in E.O. 13582 and the Syrian Sanctions Regulations. On June 17, 2020, the U.S. Department of State designated Bashar al-Assad, Maher al-Assad, and the Fourth Division pursuant to E.O. 13894.

In 2017, Taher established Castle Security and Protection LLC, a private security company that has become the informal executive arm of the Fourth Division’s Security Bureau and is responsible for providing convoy protection at Fourth Division checkpoints. Taher was also chosen to direct the collection of fees at checkpoints and internal crossings between regime and opposition areas, as well as crossings with Lebanon. In addition to Castle Security and Protection LLC, Taher has reportedly established a number of other companies that are allegedly being used to obscure and launder money collected illicitly at regime crossings and through looting. These crossings into opposition areas have generated huge sums for regime officials, and in one example, most of the sums made reportedly went to Maher al-Assad.

Taher and his company, Castle Security and Protection LLC, were both designated today pursuant to E.O. 13582 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods and services in support of, the Government of Syria. Castle Security and Protection LLC was additionally designated for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Taher.

In 2019, Taher founded Emma Tel LLC, a telecommunications provider that now has over 20 locations around Syria, where it sells mobile phone equipment and provides related services. Bashar al-Assad’s wife, Asma al-Assad, allegedly ordered the establishment of Emma Tel LLC in order to create alternatives to the business empire of Rami Makhlouf, the cousin of Bashar al-Assad, and to break the dominance of the Makhlouf-owned Syriatel Mobile Telecom on the Syrian telecommunications market. Despite the reported linkages to Asma Al-Assad, Taher established Emma Tel LLC and owns 100 percent of its shares. Furthermore, Taher recently established Ella Media Services LLC, an advertisement company that was awarded a license to manage Syria’s largest billboard advertising network.

Emma Tel LLC and Ella Media Services LLC were designated today pursuant to E.O. 13582 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Taher. Today, OFAC also issued a general license authorizing persons to wind down transactions prohibited by the Syrian Sanctions Regulations involving Emma Tel LLC, or any entity in which Emma Tel LLC owns, directly or indirectly, a 50 percent or greater interest, for 90 days, as well as an FAQ which provides further guidance on the scope of the general license and the wind down of transactions involving Emma Tell LLC. On June 17, 2020, the U.S. Department of State designated Asma Al-Assad pursuant to E.O. 13894.

Taher is also involved in a joint venture with the Syrian Transport and Tourism Company named Syrian Hotel Management LLC. Taher owns two-thirds of the shares of the joint venture, while Syrian Transport and Tourism Company owns the remaining shares. The Syrian Transport and Tourism Company itself is owned 67 percent by the Syrian Ministry of Tourism.

Syrian Hotel Management LLC was designated today pursuant to E.O. 13582 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Taher. Syrian Transport and Tourism was also designated today under E.O. 13582 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, the Government of Syria. OFAC additionally identified the Syrian Ministry of Tourism as part of the Government of Syria.

Taher further owns or controls several other companies, including Al Ali and Al Hamza LLC, Jasmine Contracting Company, Golden Star Trading LLC, Emma LLC, Ella Tourism Company, and Emma Tel Plus LLC. These companies are involved in an array of activities, including contracting, the wholesale of metals and electronics, money transfer, and tourism activities. These companies were all designated today pursuant to E.O. 13582 for being owned or controlled by or having acted or purported to act for or on behalf of, directly or indirectly, Taher. Taher additionally owns a 50 percent stake in the Syrian Company for Metals and Investments LLC, which is being identified for being owned in the aggregate, directly or indirectly, 50 percent or more by Taher.

HUSAM MUHAMMAD LOUKA – HEAD OF THE SYRIAN GENERAL INTELLIGENCE DIRECTORATE

Today, OFAC also designated Husam Muhammad Louka (Louka), the current head of the Syrian General Intelligence Directorate (GID), one of Syria’s four intelligence agencies. On April 29, 2011, the President included the GID in the Annex to E.O. 13572. On April 22, 2012, the President included the GID in the Annex to E.O. 13606, “Blocking the Property and Suspending Entry Into the United States of Certain Persons With Respect to Grave Human Rights Abuses by the Governments of Iran and Syria via Information Technology.”

Louka is a longtime leader within the Syrian regime’s security apparatus. In 2010, Louka was appointed Assistant Head of the GID. Since the Syrian revolution broke out in March 2011, Louka has held several high-ranking positions in both the Syrian Political Security Directorate and the GID, including as Head of the Political Security Branches in Homs and Hama. While working in Homs, Louka reportedly committed a number of massacres and was responsible for the torture of detainees in his department. In 2015, Louka was accused in press reporting of participating in the so-called “Eid massacre” in the al-Waer neighborhood, where a children’s playground was bombed and 19 people, including 14 children, were killed. Louka has been serving in his current position as Head of the GID since July 2019.

Louka is being designated pursuant to E.O. 13572 for being a senior official of the GID, an entity whose property and interests in property are blocked pursuant to E.O. 13572.

HAZEM YOUNES KARFOUL – GOVERNOR OF THE CENTRAL BANK OF SYRIA

Additionally, today OFAC designated the Governor of the Central Bank of Syria (CBoS), Hazem Younes Karfoul (Karfoul). The Syria Sanctions Regulations at 31 C.F.R. part 542 includes the Central Bank of Syria in the definition of Government of Syria.

In September 2018, Syrian President Bashar Al-Assad appointed Karfoul Governor of the CBoS. The CBoS, which is headquartered in Damascus, Syria, oversees the stability, integrity, and efficiency of the country’s monetary policy and acts as the fiscal agent and depository of the government. Prior to his appointment as Governor, Karfoul held other posts at the bank. In 2010, he was assigned to the CBoS’s Directorate of Economic Research and General Statistics, and later, in February 2011, he became head of the Department of Office Control and Assistant Director of the Directorate of the Government Commission. In November 2013, Karfoul worked with the Anti-Money Laundering and Terrorism Financing Authority and took the position of Secretary of Authority that same month. In 2014, Karfoul was assigned the position of First Deputy Governor of the CBoS.

As Governor of the CBoS, Karfoul met with the Governor of the Central Bank of Iran in Tehran in September 2019 to sign a memorandum of understanding for the development of strategic and long-term areas of economic cooperation. Also, in September 2019, Karfoul assembled some of Syria’s wealthiest businessmen in Damascus to seek donations in an effort to strengthen the country’s struggling currency. It was reported in the press that Karfoul identified the properties and other assets of the businessmen during the meeting and had suggested to the participants that their fortunes could be seized if they did not give a significant contribution to the state’s coffers.

Karfoul is being designated pursuant to E.O. 13573 for being a senior official of the Government of Syria and pursuant to E.O. 13582 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, the Government of Syria, a person whose property and interests in property are blocked pursuant to E.O. 13582.

SANCTIONS IMPLICATIONS

All property and interests in property of these persons that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked or designated persons. In addition, non-U.S. persons that engage in certain transactions with the persons designated today may be exposed to designation. Pursuant to the general license issued today, U.S. persons are authorized to wind down transactions with Emma Tel LLC, and any entity in which Emma Tel LLC owns, directly or indirectly, a 50 percent or greater interest, until December 20, 2020.

as did State:

Three years ago yesterday, on September 29, 2017, Assad regime forces, backed by Russia, killed at least 34 Syrians in the town of Armanaz.  Since then, thousands of Bashar al-Assad’s bombs have been dropped on schools, hospitals, and markets across Syria.  Too many lives have been lost in Assad’s futile search for a military conquest over his own people.

Today, the United States is announcing 17 Syria sanctions designations as part of the Administration’s continuing campaign to achieve the goals of the Caesar Syria Civilian Protection Act of 2019 and hold Assad and his enablers accountable for their crimes, including the killings at Armanaz and in countless other Syrian communities.

Along with the 14 designations announced by the Department of the Treasury targeting Assad’s corrupt financiers, officials, and affiliated businesses, the Department of State is issuing three designations against the 5th Corps of the Syrian Arab Army and Bashar al Assad’s personal illicit business network.  Specifically, we are designating 5th Corps commander Milad Jedid pursuant to Executive Order (E.O.) 13894 for his involvement in the obstruction, disruption, or prevention of a ceasefire in Syria.

Furthermore, we are designating Nasreen Ibrahim and Rana Ibrahim, the adult sisters of Assad financier Yasser Ibrahim, pursuant to section 2(a)(ii) of E.O. 13894.  The Ibrahim family, led by Yasser Ibrahim, acts as a front for Bashar al-Assad and his wife Asma al Akhras.  While millions of Syrians face hunger, the Ibrahims are on a spending spree to expand Assad’s and Akhras’s personal stranglehold on the Syrian economy.

As a general matter, U.S. sanctions do not target humanitarian-related trade, assistance, or activities.  In sharp contrast to the Assad regime and bad actors like the Ibrahims, the United States continues to increase its support for the Syrian people.  This includes more than $720 million announced on September 24, which brings the total U.S. humanitarian support for the Syrian people to over $12 billion since the start of the crisis.

The Administration’s designations of senior Government of Syria officials, military commanders, and corrupt business leaders will not cease until the Assad regime and its enablers take irreversible steps to end their campaign of violence against the Syrian people and genuinely implement United Nations Security Council Resolution 2254.  Thus far, Assad’s foreign enablers have only emboldened his regime’s cronies and deepened their involvement in the exploitative financial and military apparatus that underpins the regime’s survival.  There is a clear path forward.  The Syrian people have suffered enough.  Now is the time for a peaceful political resolution of the Syrian conflict as called for in UNSCR 2254.

So far, no statements on the Cuba designation.

Links:

OFAC Notice

Syria General License 20

New FAQ

Treasury Department Press Release

State Department Press Release

EU adds 7 ministers to Syria sanctions

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Syria: 7 new ministers added to the EU sanctions list

Today the Council decided to impose targeted restrictive measures on recently appointed ministers in Syria.

Today’s decision brings to 280 the number of persons targeted by a travel ban and an asset freeze. 70 entities are also listed and, as such, are subject to an assets freeze.

The sanctions currently in place against the Syrian regime were introduced in 2011, in response to the violent repression of the Syrian civilian population. They also  target companies and prominent business people benefitting from their ties with the regime and the war economy. Restrictive measures also include a ban on the import of oil, restrictions on certain investments, a freeze of the Syrian central bank’s assets that are held in the EU, export restrictions on equipment and technology that could be used for internal repression and on equipment and technology for the monitoring or interception of internet or telephone communications.

The Council keeps developments in the Syrian conflict under constant review. Any decision to prolong the sanctions is for the Council to take on an annual basis.

The EU remains committed to finding a lasting and credible political solution to the conflict in Syria on the basis of UN Security Council resolution 2254 and the 2012 Geneva Communiqué.

The relevant legal acts, including the names of the persons and entities concerned, have been published in the Official Journal.

Link:

EU Notice

Official Journal of the EU for October 16, 2020

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