Litigation

Sanctions Round Up First Quarter 2022

Shearman & Sterling LLP

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10 COUNTERTERRORISM DESIGNATIONS Twice in January, OFAC acted against a foreign terrorist organization, Hizballah, primarily targeting individuals and entities alleged to be operating in the Hizballah network in Lebanon. On January 18, OFAC designated Adel Diab, a Hizballah member and Lebanese businessman, Ali Mohamad Daoun, a Hizballah official in charge of its second district, and Jihad Salem Alame, a Hizballah member, for having provided material support to Hizballah. OFAC further designated Lebanese travel agency Dar Al Salam for Travel & Tourism, which is owned by Diab, Daoun, and Alame. On January 21, OFAC designated Adel Diab's son, Ali Adel Diab, a Lebanese national and director and partner of Zambia-based Hamer and Nail Construction, which OFAC also designated for providing material support to Hizballah along with another Zambia-based entity, Hamidco Investment Limited. OFAC further designated Adnan Ayad and his son Jihad Adnan Ayad, both alleged to be Hizballah members, and related entity Al Amir Co. for Engineering, Construction, and General Trade SARL, which the Ayads reportedly used to raise funds and launder money for Hizballah. Finally, OFAC designated the following entities for being part of Adnan Ayad and Adel Diab's networks: Golden Group SAL Offshore, Inshaat Co SARL, Land Metics SARL, Land Metics SAL Off-Shore, Golden Group Trading SARL, Top Fashion Gmbh Konfektionsb├╝gelei, and Jammoul and Ayad Industry for Trade. On February 3, OFAC sanctioned World Human Care, a non-governmental organization based in Indonesia reportedly established by the terrorist organization, Majelis Mujahidin Indoensia ("MMI"). According to OFAC, MMI claims to be a "charitable organization" but is a front for violent extremist activity in Syria. MMI reportedly hosted fundraisers in Indonesia, then transferred those funds to people and groups in Syria affiliated with Al Qaeda. The designation of World Human Care illustrates the difficulties OFAC faces in encouraging and supporting legitimate humanitarian organizations while preventing the financing of terrorism. In its sanctions announcement, OFAC emphasized that organizations like World Human Care undermine legitimate humanitarian efforts. On February 23, OFAC designated members of an international network funding the Houthis' war in Yemen, led by the Islamic Revolutionary Guard Corps Qods Force and previously designated Houthi financier Sa'id al-Jamal and Turkey-based businessman Abdi Nasir Ali Mahamud. According to OFAC, the network has used a complex

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