Litigation

Sanctions Roundup Third Quarter 2021

Shearman & Sterling LLP

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12 COUNTERTERRORISM DESIGNATIONS On July 28, OFAC designated numerous entities and individuals connected with terrorist efforts in Syria. OFAC identified two individuals alleged to have provided financial support to Al Qaeda and Hay'at Tahrir al-Sham, a militant group involved in the Syrian civil war. According to OFAC, bank accounts linked to Hasan Al-Shaban, based in Turkey, were used in connection with an Al Qaeda fundraiser to transfer funds to Turkey and across North Africa, Western Europe, and North America in support of Al Qaeda military efforts in Syria. Separately, OFAC designated Farrukh Furkatovitch Fayzimatov for spreading propaganda and soliciting donations for Hay'at Tahrir al-Sham. Both are designated for providing material financial support to terrorist groups. OFAC additionally identified four individuals connected with Syrian Military Intelligence. According to OFAC, Military Intelligence branch heads Asef Al-Deker and Malik Ali Habib were involved in massacres in the Syrian conflict and murders of detainees at the Tadmur Branch of Syrian Military Intelligence, respectively. Additionally, OFAC designated military intelligence head Kifah Moulhem for human rights abuses at detention facilities he oversaw. Further, OFAC designated Wafiq Nassser for widespread human rights abuses against civilians. In connection with these human rights abuses, OFAC also designated six branches of the Syrian Military Intelligence (Branches 215, 216, 227, 235, 248, and 290) and Saydnaya Military Prison. OFAC finally designated Syrian General Intelligence Directorate (GID) Branch 251 and Ahmed Al-Dib for human rights abuses under E.O. 13572 for being owned or controlled by the Syrian GID. Finally, OFAC designated Ahrar al-Sharqiya, a Syrian armed group with a record of human rights abuses, including the killing of a Kurdish politician. The UN previously identified the murder as a possible war crime. Two members of the group, Ahmad Ihsan Fayyad al-Hayes and Raed Jassim al-Hayes have also been designated for their participation in human rights abuses in connection with Ahrar al-Sharqiya. On August 6, the U.S. State Department and OFAC designated five terrorist leaders in Africa as Specially Designated Global Terrorists pursuant to E.O. 13224. In West Africa, OFAC and the State Department designated Sidan Ag Hitta and Salem ould Breihmatt, leaders of the terrorist group Jama'at Nasr al-Islam wal Muslimin (JNIM), who oversaw attacks in Mali and Burkina Faso. JNIM is an Al-Qaeda affiliated terrorist group operating primarily in the Islamic Magrheb. In East Africa, OFAC and the State Department designated two members of Somalia-based terrorist group al Shabaab, Ali Mohamed Rage and Abdikadir Mohamed Abdikadir. Finally,

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