Litigation

Sanctions Roundup Third Quarter 2021

Shearman & Sterling LLP

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13 OFAC designated Bonomade Machude Omar, the leader of the Military and External Affairs Departments of ISIS-Mozambique. According to the State Department, Omar led attacks in Mozambique and Tanzania. On August 13, OFAC designated individuals and entities alleged to have smuggled oil in support of Iran's Islamic Revolutionary Guard Corp-Qods Force. According to OFAC, Mahmood Rashid Amur Al Habsi, an Omani national, transported tens of millions of dollars of oil through Nimr International LLC and Orbit Petrochemicals Trading LLC. OFAC also designated Liberia-based Bravery Maritime Corporation and Romania-based Nimr International SRL for being owned directly or indirectly by Al Habsi. On September 16, OFAC designated five Turkish and Egyptian nationals operating in Turkey for providing material support to Al Qaeda. OFAC designated Egyptian-born lawyer Majdi Salim and Egyptian national Muhammad Nasr al-Din al-Ghazlani for facilitating the transfer of funds to Al Qaeda. OFAC also designated Turkish nationals Nurettin Muslihan, Cebrail Guzel, and Soner Gurleyen for facilitating financing and providing support to Al Qaeda. On September 24, OFAC issued General License 14, authorizing humanitarian activities, and General License 15, authorizing certain transactions related to the exportation of agricultural commodities, medicine, medical devices, and software, in Afghanistan. These licenses follow the recent imposition of sanctions on the Taliban and the Haqqani Network and are designed to ensure critical humanitarian assistance reaches Afghan civilians without undue burden. General License 14 applies to the U.S. government, American nongovernmental organizations, the U.N. and affiliated specialized agencies, ICSID and the Multilateral Investment Guarantee Agency, the African Development Bank Group, the Asian Development Bank, the European Bank for Reconstruction and Development, the Inter-American Development Bank Group, the International Committee of the Red Cross and the International Federation of Red Cross and Red Crescent Societies, and the Islamic Development Bank. Finally, on September 29, OFAC and the Government of Qatar jointly sanctioned a major Hizballah financial network operating in the Arabian Peninsula. OFAC identified Ali Reda Hassan al-Banai, Ali Reda al-Qassabi Lari, and Abd al-Muyyid al-Banai, operating in Kuwait, as Specially Designated Global Terrorists for providing material support to Hizballah, which has been designated as a Foreign Terrorist Operation since 1997. According to OFAC, Ali al-Binai and Ali Lari provided tens of millions of dollars to Hizballah and a Kuwait-based branch of U.S.-sanctioned Martyrs Foundation. OFAC additionally designated Abd al-Rahman Abd al-Nabi Shams, Yahya Muhammad al-Abd-al-Muhsin, Majdi Fa'iz al-Ustadz, and Sulaiman al-Banai for providing material support to Ali al-Banai, including coordinating real estate projects in Bahrain, Saudi Arabia, and the United Arab Emirates. OFAC finally designated AlDar Properties, a Qatar property management company, for being owned or controlled by Sulaiman al-Banai.

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