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Where in the world is OFAC today? Syria and Cuba

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

Categories: Cuba Sanctions Frequently Asked Questions (FAQ) Guidance Licenses OFAC Updates Sanctions Lists Syrian Sanctions Syrian-related sanctions

eric9to5

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