January 22, 2019: Here’s OFSI’s Syria changes we told you about

As the prior notice stated, HM Treasury’s Consolidated List was updated a day late because the EU changes were so late…

Council Implementing Regulation (EU) 2019/85 has caused the following additions to the Syria sanctions regime – persons:

1. TALAS, Anas

DOB: 25/03/1971. a.k.a: (1) TALOUS, Anas (2) TALS, Anas (3) TLASS,

Anas (4) TULS, Anas Nationality: Syrian Position: Chairman of the Talas

Group Other Information: Leading businessperson operating in Syria, with interests and activities in multiple sectors of Syria’s economy. Through his business activities and investments, Anas Talas also benefits from and/or supports the Syrian regime. In 2018 the Talas Group, chaired by Anas Talas, entered into a SYP 23 billion joint venture with Damascus Cham Holding for the construction of Marota City, a regime-backed luxury residential and commercial development. Listed on: 22/01/2019 Last Updated: 22/01/2019 Group ID: 13752.

2. JAMALEDDINE, Nazir Ahmad

DOB: –/–/1962. a.k.a: JAMALEDDINE, Nazir, Ahmad, Mohammed

Nationality: Syrian Position: Cofounder and majority shareholder of Apex Development and Projects LLC and founder of A’ayan Company for Projects and Equipment Other Information: Leading businessperson operating in Syria with significant investments in the construction industry, including a controlling 90 % stake in Apex Development and Projects LLC, which has entered into a USD 34,8 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, Nazir Ahmad JamalEddine benefits from and/or supports the Syrian regime. Listed on: 22/01/2019 Last Updated: 22/01/2019 Group ID: 13753.

3. AL-TARAZI, Mazin

DOB: –/09/1962. a.k.a: AL-TARAZI, Mazen Position: Businessperson Other Information: Leading businessperson operating in Syria, with significant investments in the construction and aviation sectors. Through his investments and activities, Mazin Al-Tarazi benefits from and/or supports the Syrian regime. In particular, Al-Tarazi has concluded a deal with Damascus Cham Holdings for a USD 320 million investment in the construction of Marota City, a regime-backed luxury residential and commercial development, he has also been granted a licence for a private airline in Syria. Listed on: 22/01/2019 Last Updated: 22/01/2019 Group ID: 13754.

4. FOZ, Samer

DOB: –/05/1973. POB: Latakia, Syria a.k.a: (1) FAWZ, Samir (2) FOZ, Samer, Zuhair (3) FOZ, Samir Nationality: Syrian, Turkish Position: CEO of Aman Group Other Information: Leading businessperson operating in Syria, with interests and activities in multiple sectors of Syria’s economy, including a regime- backed joint venture involved in the development of Marota City, a luxury residential and commercial development. Samer Foz provides financial and other support to the regime, including funding the Military Security Shield Forces in Syria and brokering grain deals. He also benefits financially from access to commercial opportunities through the wheat trade and reconstruction projects as a result of his links to the regime. Executive President of Aman Group. Subsidiaries: Foz for Trading, Al-Mohaimen for Transportation & Contracting. Aman Group is the private sector partner in Joint Venture Aman Damascus JSC with Damascus Cham Holding, in which Foz is an individual shareholder. Emmar Industries is a joint venture between Aman Group and the Hamisho Group, in which Foz has the majority stake and is the Chairman. Listed on: 22/01/2019 Last Updated: 22/01/2019 Group ID: 13755.

5. AL-ZOUBI, Khaldoun

DOB: –/–/1979. a.k.a: (1) AL-ZU’BI, Khaldoon (2) ZUBI, Khaldoun Nationality: Syrian Position: Vice-president of Aman Holding (a.k.a. Aman Group) Other Information: Leading businessperson operating in Syria, with interests and activities in multiple sectors of Syria’s economy, including his roles as Vice President of Aman Holding and majority shareholder of Fly Aman airline. In this capacity, he is linked to Samer Foz. Aman Holding is represented on the board of, and holds a majority stake in, ‘Aman Damascus’, a joint venture in the construction of Marota City, a regime-backed luxury residential and commercial development. Al-Zoubi benefits from and/or supports the regime through his position as Vice President of Aman Holding. Listed on: 22/01/2019 Last Updated: 22/01/2019 Group ID: 13757.

6. AL-QATIRJI, Hussam

DOB: –/–/1982. POB: Raqqa, Syria a.k.a: (1) AL-KATERJI, Hossam,

Ahmed (2) AL-KATERJI, Hossam, Mohammed (3) AL-KATERJI, Hossam, Muhammad (4) AL-KATERJI, Hussam, Ahmed (5) AL-KATERJI, Hussam, Mohammed (6) AL-KATERJI, Hussam, Muhammad Nationality: Syrian Position: CEO of Katerji Group (a.k.a. al-Qatirji Company/Qatirji Company/Khatirji Group/Katerji International Group) Other Information: Leading businessperson operating in Syria, who is also a Member of Parliament for Aleppo. Al-Qatirji supports and benefits from the regime through enabling, and profiting from, trade deals with the regime in relation to oil and wheat. Listed on: 22/01/2019 Last Updated: 22/01/2019 Group ID: 13758.

7. ASSI, Bashar Mohammad

DOB: –/–/1977. Nationality: Syrian Position: Chairman of the Board of Directors of ‘Aman Damascus’. Founding partner of Fly Aman Limited Liability airline. Other Information: Leading businessperson operating in Syria, with interests and activities in multiple sectors of Syria’s economy, including his roles as founding partner of Fly Aman airline and Chairman of the Board of Directors of ‘Aman Damascus’, a joint venture involved in the development of Marota City, a regime-backed luxury residential and commercial development. Assi benefits from and/or supports the regime through his position as Chairman of the Board of Directors of ‘Aman Damascus’. Listed on: 22/01/2019 Last

Updated: 22/01/2019 Group ID: 13759.

8. AL-ZUBAIDI, Khaled

a.k.a: (1) AL-ZUBAIDI, Mohammed, Khaled, Bassam (2) AL-ZUBAIDI, Mohammed, Khalid, Bassam (3) AL-ZUBEDI, Mohammed, Khaled, Bassam (4) AL-ZUBEDI, Mohammed, Khalid, Bassam Nationality: Syrian Other Information: Co-owner of Zubaidi and Qalei LLC, Director of Agar Investment Company, General Manager of Al Zubaidi company and Al Zubaidi & Al Taweet Contracting Company, Director and Owner of Zubaidi Development Company, and co-owner of Enjaz Investment Company. Listed on: 22/01/2019 Last Updated: 22/01/2019 Group ID: 13760.

9. QADDOUR, Hayan Mohammad Nazem

DOB: –/–/1970. a.k.a: NAZEM, Hayyan, Kaddour, bin,

Mohammed Nationality: Syrian 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: 22/01/2019 Group ID: 13761.

10.HAYKAL,MaenRizk 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 Group ID: 13762.

11.QALEI, Nader

DOB: 09/07/1965. POB: Damascus, Syria a.k.a: (1) KALAI, Nader (2) KALEI, Nader Nationality: Syrian Passport Details: (including country that issued and date and place of issue): Syrian Arab Republic, N 010170320, issue number: 002- 15-L062672, date of issue: 24.5.2015, date of expiry: 23.5.2021 National Identification no: 010-40036453 (Syrian Arab Republic) Address: Young Avenue, Halifax, Canada. Position: Majority shareholder of Castle Investment Holding, Co-owner of Zubaidi and Qalei LLC, Chairman of Kalai Industries Management Other Information: Leading businessperson operating in Syria, with significant investments in the construction industry, including a 50 % stake in Zubaidi and Qalei LLC, which is constructing the luxury tourist city Grand Town and to which the regime has granted a 45-year agreement in return for 19-21 % of its revenue. In this capacity, he is linked to Khaled al-Zubaidi. Nader Qalei benefits from and/or supports the regime through his business activities, in particular through this stake in the Grand Town development. Relatives/business associates or partners/links to listed individuals: Khaled al-Zubaidi. Listed on: 22/01/2019 Last Updated: 22/01/2019 Group ID: 13763

And entities:

1. RAWAFED DAMASCUS PRIVATE JOINT STOCK COMPANY

a.k.a: (1) Rawafed Tributary Damascus Private Joint Stock Company (2) Rawafid Tributary Damascus Private Joint Stock Company Address: Damascus,

Syria. Other Information: Rawafed Damascus Private Joint Stock Company is a USD 48,3 million joint venture between Damascus Cham Holdings, Ramak Development and Humanitarian Projects, Al-Ammar LLC, Timeet Trading LLC (also referred to as Ultimate Trading Co. Ltd.), and Wings Private JSC. Rawafed supports and/or benefits from the Syrian regime, including through its participation in the regime-backed luxury development Marota City. Listed on: 22/01/2019 Last Updated: 22/01/2019 Group ID: 13764.

2. AMAN DAMASCUS JOINT STOCK COMPANY

a.k.a: Aman Damascus JSC Address: Damascus, Syria. Other

Information: Aman Damascus Joint Stock Company is a USD 18,9 million joint venture between Damascus Cham Holdings and Aman Group. Through its participation in the regime-backed luxury development Marota City, Aman Damascus supports and/or benefits from the Syrian regime. Listed

on: 22/01/2019 Last Updated: 22/01/2019 Group ID: 13765.

3. BUNYAN DAMASCUS PRIVATE JOINT STOCK COMPANY

a.k.a: Bunyan Damascus Private JSC Address: Damascus, Syria. Other Information: Bunyan Damascus Private Joint Stock Company is a USD 34,8 million joint venture between Damascus Cham Holdings and Apex Development and Projects LLC and Tamayoz LLC. Through its participation in the regime-backed luxury development Marota City, Bunyan Damascus Private Joint Stock Company supports and/or benefits from the Syrian regime. Listed on: 22/01/2019 Last Updated: 22/01/2019 Group ID: 13766.

4. MIRZA

Address: Damascus, Syria. Other Information: Mirza is a USD 52,7 million joint venture between Damascus Cham Holding and Talas Group. Through its participation in the regime-backed luxury development Marota City, Mirza supports and/or benefits from the Syrian regime. Listed on: 22/01/2019 Last

Updated: 22/01/2019 Group ID: 13767.

5. 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 Group

ID: 13768.

Links:

OFSI Notice

Council Implementing Regulation (EU) 2019/85

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