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OFAC adds to counter-terror, Syria & Syria-related programs… and makes some updates

OFAC today added the following persons:

AL-SHABAN, Hasan (a.k.a. ALSHABAN, Hasan Suliman), Manbij, Syria; Sahinbey, Gaziantep, Turkey; DOB 07 Jan 1987; nationality Syria; Gender Male; Passport 02812L004397 (Syria); Identification Number 02120304806 (Syria); alt. Identification Number N006695928 (Syria); alt. Identification Number 99071138750 (Turkey) (individual) [SDGT]. 

FAYZIMATOV, Farrukh Furkatovitch (a.k.a. AL-SHAMI, Faruk; a.k.a. ASH-SHAMI, Faruk; a.k.a. FAYZIMATOV, Faruk Furkatovich; a.k.a. SHAMI, Faruk; a.k.a. SHAMI, Faruq (Cyrillic: ШАМИ, Фарук)), Idlib, Syria; DOB 02 Mar 1996; citizen Tajikistan; Gender Male; Digital Currency Address - XBT 17a5bpKvEp1j1Trs4qTbcNZrby53JbaS9C (individual) [SDGT].

to its counter-terrorism sanctions program, and:

AL-DEKER, Asef (a.k.a. AL-DIKR, Asf; a.k.a. DAKKAR, Asef), Syria; DOB 1965; POB Jableh, Beit Yashout, Syria; nationality Syria; Gender Male; Brigadier General (individual) [SYRIA] (Linked To: SYRIAN MILITARY INTELLIGENCE DIRECTORATE). 

AL-DIB, Ahmed (Arabic: احمد الدیب) (a.k.a. DEEB, Ahmad; a.k.a. DEEB, Ahmed; a.k.a. DIB, Ahmad; a.k.a. DIB, Ahmed (Arabic: احمد دیب); a.k.a. DIBE, Ahmad; a.k.a. DIBE, Ahmed (Arabic: احمد دیبئ)), Damascus, Syria; DOB 1961; POB Ayn Al-Tineh Village, Latakia, Syria; nationality Syria; Gender Male; Brigadier General (individual) [SYRIA] (Linked To: SYRIAN GENERAL INTELLIGENCE DIRECTORATE).

HABIB, Malik Ali (Arabic: مالک علئ حبیب), Palmyra, Syria; DOB 04 Jan 1963; POB Jablah Latakia, Syria; nationality Syria; Gender Male; Major General (individual) [SYRIA] (Linked To: SYRIAN MILITARY INTELLIGENCE DIRECTORATE).

NASSER, Wafiq (Arabic: وفیق ناصر) (a.k.a. NASER, Wafiq; a.k.a. NASSEER, Wafiq), Aleppo, Syria; DOB 10 Jul 1964; POB Jableh, Syria; nationality Syria; Gender Male; Brigadier General (individual) [SYRIA] (Linked To: SYRIAN MILITARY INTELLIGENCE DIRECTORATE).

to its Syria sanctions program, and:

AL-HAYES, Ahmad Ihsan Fayyad (Arabic: أحمد إحسان فیاض الهایس) (a.k.a. AL-HAYES, Ahmed Ihsan Fayyad; a.k.a. AL-SHAQRA, Abu Hatim; a.k.a. SHAKRA, Abu Hatem; a.k.a. SHAQRA, Abu Hatim; a.k.a. SHAQRA, Abu Hattam), Syria; DOB 1987; POB Al-Shaqra, Deir ez-Zor, Syria; nationality Syria; Gender Male (individual) [SYRIA-EO13894] (Linked To: AHRAR AL-SHARQIYA). 

AL-HAYES, Raed Jassim (a.k.a. AL-HAYES, Raed Jassem; a.k.a. CHAKRA, Abu Jaafar; a.k.a. SHAKRA, Abu Jaafar; a.k.a. SHAQRA, Abu Ja'far; a.k.a. SHAQRA, Abu Jafar), Syria; DOB 1985; nationality Syria; Gender Male (individual) [SYRIA-EO13894].

to its Syria-related sanctions program.

Similarly, the following entities were added to the Syria sanctions:

SYRIAN GENERAL INTELLIGENCE BRANCH 251 - AL-KHATIB (a.k.a. "AL-KHATEEB BRANCH" (Arabic: "فرع الخطيب"); a.k.a. "BRANCH 251" (Arabic: "الفرع 251"); a.k.a. "BRANCH 251-AL-KHATEEB"; a.k.a. "THE INTERIOR BRANCH" (Arabic: "الفرع الداخلي")), al-Khatib area of Baghdad Street, Damascus, Syria [SYRIA] (Linked To: SYRIAN GENERAL INTELLIGENCE DIRECTORATE). 

SYRIAN MILITARY INTELLIGENCE BRANCH 215 - RAIDS (a.k.a. "BRANCH 215" (Arabic: "الفرع 215"); a.k.a. "BRANCH 215: RAIDS COMPANY" (Arabic: "سرية المداهمة والاقتحام"); a.k.a. "KAFRSOUSA BRANCH"; a.k.a. "RAIDS COMPANY" (Arabic: "فرع سرية المداهمة")), Syria; 6th of May Street, Damascus, Syria [SYRIA] (Linked To: SYRIAN MILITARY INTELLIGENCE DIRECTORATE).

SYRIAN MILITARY INTELLIGENCE BRANCH 216 (Arabic: الفرع 216) (a.k.a. "BRANCH 216: PATROLS BRANCH" (Arabic: "فرع الدوريات")), Damascus, Syria [SYRIA] (Linked To: SYRIAN MILITARY INTELLIGENCE DIRECTORATE).

SYRIAN MILITARY INTELLIGENCE BRANCH 227 - AL MINTAQA BRANCH (Arabic: رع المنطقة) (a.k.a. "AL-MINTAQA"; a.k.a. "AL-MINTAQA BRANCH 227"; a.k.a. "BRANCH 227" (Arabic: "الفرع 227"); a.k.a. "BRANCH 227: DAMASCUS GOVERNORATE BRANCH"), 6th of May Street, Damascus, Syria [SYRIA] (Linked To: SYRIAN MILITARY INTELLIGENCE DIRECTORATE).

SYRIAN MILITARY INTELLIGENCE BRANCH 235 - PALESTINE (a.k.a. "BRANCH 235" (Arabic: "الفرع 235"); a.k.a. "BRANCH 235: PALESTINE BRANCH" (Arabic: "فرع فلسطين")), Damascus, Syria [SYRIA] (Linked To: SYRIAN MILITARY INTELLIGENCE DIRECTORATE).

SYRIAN MILITARY INTELLIGENCE BRANCH 248 - INVESTIGATION (Arabic: فرع التحقيق; Arabic: فرع 248) (a.k.a. BRANCH 248 MILITARY INTELLIGENCE (Arabic: فرع التحقيق العسكري)), Al Tawajoh Street, Alsyasi Street, 6th of May Street, Damascus, Syria [SYRIA] (Linked To: SYRIAN MILITARY INTELLIGENCE DIRECTORATE).

SYRIAN MILITARY INTELLIGENCE BRANCH 290 - ALEPPO BRANCH (a.k.a. "BRANCH 290"), Aleppo, Syria [SYRIA] (Linked To: SYRIAN MILITARY INTELLIGENCE DIRECTORATE).

and to the Syria-related sanctions:

AHRAR AL-SHARQIYA (Arabic: أحرار الشرقية) (a.k.a. AHRAR AL-SHARQIAH; a.k.a. AHRAR AL-SHARQIYA BRIGADE; a.k.a. AHRAR AL-SHARQIYAH; a.k.a. AHRAR AL-SHARQIYEH; a.k.a. GATHERING OF THE FREEMEN OF THE EAST; a.k.a. TAJAMMU' AHRAR AL-SHARQIYA), Syria [SYRIA-EO13894]. 

SARAYA AL-AREEN (Arabic: سرايا العرين) (a.k.a. ABU AL-HARETH MILITIA; a.k.a. SARAYA AL-'AREEN; a.k.a. "AL-AREEN 13"), Latakia, Syria [SYRIA-EO13894].

SAYDNAYA MILITARY PRISON (Arabic: سجن صيدنايا العسكري) (a.k.a. SAIDNAYA MILITARY PRISON; a.k.a. SAYDNAYA PRISON; a.k.a. SEDNAYA PRISON (Arabic: سجن صيدنايا)), Syria [SYRIA-EO13894].

Finally, OFAC updated the following existing listings (one for Syria, and one for the Syria-related program):

MOULHEM, Kifah (Arabic: كفاح ملحم) (a.k.a. AL-MILHEM, Kifah; a.k.a. MELHEM, Kifah; a.k.a. MILHEM, Kifah; a.k.a. MOULHIM, Kifah; a.k.a. MULHEM, Kifah; a.k.a. MULHIM, Kifah), Damascus, Syria; DOB 28 Nov 1961; POB Junayrat Ruslan, Tartous, Syria; nationality Syria; Gender Male (individual) [SYRIA-EO13894]. -to- MOULHEM, Kifah (Arabic: كفاح ملحم) (a.k.a. AL-MILHEM, Kifah; a.k.a. MELHEM, Kifah; a.k.a. MILHEM, Kifah; a.k.a. MOULHIM, Kifah; a.k.a. MULHEM, Kifah; a.k.a. MULHIM, Kifah), Damascus, Syria; DOB 28 Nov 1961; POB Junayrat Ruslan, Tartous, Syria; nationality Syria; Gender Male (individual) [SYRIA] [SYRIA-EO13894] (Linked To: SYRIAN MILITARY INTELLIGENCE DIRECTORATE). 

SYRIAN MILITARY INTELLIGENCE, Syria [SYRIA]. -to- SYRIAN MILITARY INTELLIGENCE DIRECTORATE (Arabic: شعبة المخابرات العسكرية سوربا) (a.k.a. SHU'BAT AL-MUKHABARAT AL-'ASKARIYYA; a.k.a. SYRIAN MILITARY INTELLIGENCE), Syria; Organization Established Date 1969 [SYRIA].

And Treasury issued press releases for the counter-terror designations:

PRESS RELEASES

Treasury Designates Al-Qa’ida-Linked Financial Facilitators in Turkey and Syria

July 28, 2021

WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated one Turkey-based al-Qa’ida financial facilitator for materially assisting al-Qa’ida. Additionally, OFAC designated one Syria-based terrorist fundraiser and recruiter for providing material support to Hay’et Tahrir Al-Sham (HTS). These designations expose the continued efforts by al-Qa’ida and HTS to use the global formal financial system and highlight the need for continued vigilance against terrorist fundraising and recruitment on the internet.

“Terrorist groups like al-Qa’ida and HTS continue to raise funds, recruit online, and exploit the international banking sector to support their ongoing terrorist activities,” said Office of Foreign Assets Control Director Andrea Gacki. “These designations underscore this Administration’s commitment to disrupting support networks of al-Qa’ida and other terrorist groups that seek to attack the United States and its allies.”

HASAN AL-SHABAN

Al-Shaban’s banking information was provided by an al-Qa’ida fundraiser to prospective donors as a way for them to send money to support al-Qa’ida military efforts and the so-called mujahideen fighting in Syria. Members of al-Qa’ida utilized bank accounts associated with al-Shaban to coordinate the movement of money from associates across North Africa, Western Europe, and North America, and separately used al-Shaban to coordinate the transfer of funds to Turkey.

Al-Shaban is being designated pursuant to Executive Order (E.O.) 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, al-Qa’ida.

FARRUKH FURKATOVITCH FAYZIMATOV

Fayzimatov utilizes social media to post propaganda, recruit new members, and solicit donations for HTS. Fayzimatov organized community fundraising campaigns to purchase equipment for the benefit of HTS, including motorbikes.

Fayzimatov is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of HTS.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of these individuals named above, and of any entities that are owned, directly or indirectly, 50 percent or more by them, individually, or with other blocked persons, that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. Unless authorized by a general or specific license issued by OFAC or otherwise exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated or otherwise blocked persons.

Furthermore, engaging in certain transactions with the individuals designated today entails risk of secondary sanctions pursuant to E.O. 13224, as amended. Pursuant to this authority, OFAC can prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account by a foreign financial institution that either knowingly conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist.

and for the Syria (& related) designations:

PRESS RELEASES

Treasury Sanctions Syrian Regime Prisons, Officials, and Syrian Armed Group

July 28, 2021

WASHINGTON – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is sanctioning eight Syrian prisons run by the Assad regime’s intelligence apparatus, which have been sites of human rights abuses against political prisoners and other detainees. OFAC is also designating five senior security officials of regime entities that control these detention facilities. The Assad regime has waged a ruthless war against the Syrian people, imprisoning hundreds of thousands of Syrians calling for reform and change, of whom at least 14,000 have been tortured to death. More than 130,000 people reportedly remain missing or arbitrarily detained to this day—the vast majority of whom are either presumed dead or are detained without communication with family or legal representation.

OFAC is also sanctioning Syrian armed group Ahrar al-Sharqiya, which operates in northern Syria, for abuses against civilians, and is also sanctioning two of the group’s leaders. Ahrar al-Sharqiya has committed numerous crimes against civilians, particularly Syrian Kurds, including unlawful killings, abductions, torture, and seizures of private property. The group has also incorporated former Islamic State of Iraq and Syria (ISIS) members into its ranks. These horrific acts compound the suffering of a population that has repeatedly endured mass displacement.

“Today’s designations promote accountability for abuses committed against the Syrian people and deny rogue actors access to the international financial system,” said Director of the Office of Foreign Assets Control Andrea M. Gacki. “This action demonstrates the United States’ strong commitment to targeting human rights abuses in Syria, regardless of the perpetrator.”

This action furthers the objectives of the Caesar Syria Civilian Protection Act of 2019 (Caesar Act), which seeks to hold the Assad regime accountable for commission of atrocities against those detained in its prisons. Many of the prisons designated today, which are operated as branches of the Syrian Military Intelligence and the Syrian General Intelligence Directorate, were specifically highlighted in images provided by Caesar, a Syrian regime defector—in whose name the Caesar Act was passed into law—who worked as an official forensic photographer for the Syrian military and who bravely brought to light thousands of images of detainees who were tortured and killed.

On May 18, 2011, Treasury designated Syrian Military Intelligence, one of the four branches of Syria’s security forces, for using force against and arresting demonstrators participating in civil unrest in Syria. Syrian Military Intelligence’s notorious branches in Damascus and Aleppo have become known for the abuses committed against detainees, including numerous political prisoners, held in these facilities. On April 29, 2011, Treasury designated the Syrian General Intelligence Directorate, the overarching civilian intelligence service in Syria.

Today’s actions were taken pursuant to Executive Order (E.O.) 13894 of October 14, 2019, which imposes sanctions on those responsible for, complicit in, or having engaged in commission of serious human rights abuse in Syria, as well as E.O. 13572 of September 28, 2010, which imposes sanctions on certain persons responsible for or complicit in human rights abuses in Syria, as well as senior officials of, or entities owned or controlled by, persons designated pursuant to E.O. 13572.

SAYDNAYA MILITARY PRISON

Operated by Syrian Military Intelligence, Saydnaya Military Prison has a well-documented history of serious human rights abuses. Since the beginning of the crisis in Syria, both peaceful opponents of the regime as well as military personnel suspected of opposing the regime were detained and perished in the prison. Two buildings at the Saydnaya Military Prison site alone could contain as many as 10,000 to 20,000 detainees between them. Many prisoners have been denied food and water for prolonged periods of time and were subjected to extensive beatings. Thousands of Syrian regime dissidents reportedly have been extrajudicially executed in mass hangings at the prison and buried in mass graves. Several reports by non-governmental organizations estimate that between 5,000 and 13,000 people were executed at Saydnaya Military Prison between 2011 and 2015. Reports smuggled out from detainees at Saydnaya Military Prison since then indicated that the rate of extrajudicial killings at the prison has accelerated.

Saydnaya Military Prison is being designated pursuant to E.O. 13894 for having engaged in the commission of serious human rights abuse.

SYRIAN MILITARY INTELLIGENCE BRANCHES AND SENIOR OFFICIALS

Prisons operated by Syrian Military Intelligence Branch 215, Branch 216, Branch 227, Branch 235, Branch 248, and Branch 290 reportedly have been the sites of numerous human rights violations and abuses perpetrated by the Assad regime since the start of the Syrian conflict. The Caesar photos revealed that 8,382 detainees were injured in detention in Syrian Military Intelligence Branch 215, Branch 216, Branch 227, Branch 235, Branch 248, and Branch 290. Syrian Military Intelligence Branch 215, Branch 216, Branch 227, Branch 235, Branch 248, and Branch 290 have all been identified by the Independent International Commission of Inquiry on Syria, which was established by the United Nations Human Rights Council, as facilities where death in detention and human rights abuses have occurred.

Syrian Military Intelligence Branch 215, Branch 216, Branch 227, Branch 235, Branch 248, and Branch 290 are being designated pursuant to E.O. 13572 for being owned or controlled by Syrian Military Intelligence.

Syrian Military Intelligence head Kifah Moulhem reportedly oversaw detention facilities where human rights abuses occurred. Prior to being named to his current role, Moulhem commanded Syrian Military Intelligence Branch 248, where he reportedly supervised the torture and killing of many detainees. On December 22, 2020, the U.S. Department of State designated Moulhem pursuant to E.O. 13894 for being complicit in, having directly or indirectly engaged in, or attempted to engage in, or financed, the obstruction, disruption, or prevention of a ceasefire in northern Syria.

Wafiq Nasser, commander of Syrian Military Intelligence Branch 290, reportedly has been associated with numerous kidnappings, murders, and assassinations. Previously, while serving as a Colonel in Syria’s Republican Guard, Nasser participated in the regime’s first raids on Daraa, where he reportedly committed widespread abuses against civilians. Nasser was also reported to have been personally involved in the arrest and torture of a dissident within the Syrian military.

Syrian Military Intelligence Branch head Asef Al-Deker was involved in one of the largest massacres of the Syrian conflict, during which approximately 2,000 Syrian and Palestinian civilians reportedly were killed or disappeared at a Syrian Military Intelligence training school under his control.

Syrian Military Intelligence Branch head Malik Ali Habib played a major role in crimes and violations committed by the Tadmur Branch of Syrian Military Intelligence, including the murders of detainees at that branch. Dozens of bodies of deceased detainees had been seen at the Tadmur Branch during Habib’s tenure. Political prisoners reportedly under Habib’s supervision were beaten, burned, and crucified to death; officials were then forced to write reports that the prisoners died of natural causes, such as stroke and kidney failure.

Moulhem, Nasser, Al-Deker, and Habib are being designated pursuant to E.O. 13572 for being senior officials of Syrian Military Intelligence.

SYRIAN GENERAL INTELLIGENCE DIRECTORATE (GID) BRANCH 251 AND AHMED AL-DIB

GID Branch 251, led by Al-Dib, has been identified by the Independent International Commission of Inquiry on Syria which was established by the United Nations Human Rights Council, as a facility controlled by the Syrian GID where death in detention and torture have occurred. Al-Dib has a long history as a senior official of the Syrian GID and has been implicated in reports of arbitrary detention and torture of detainees since at least 2011.

Syrian General Intelligence Branch 251 is being designated pursuant to E.O. 13572 for being owned or controlled by the Syrian GID. Al-Dib is being designated pursuant to E.O. 13572 for being a senior official of the Syrian GID.

AHRAR AL-SHARQIYA

Syrian armed group Ahrar al-Sharqiya has a record of human rights abuse that includes the unlawful killing of Hevrin Khalaf, a Kurdish politician and Secretary General of the political party Future Syria, as well as her bodyguards in October 2019. The United Nations High Commissioner for Human Rights identified the murders as a possible war crime. Ahrar al-Sharqiya has killed multiple civilians in northeast Syria, including health workers. The militia has also engaged in abductions, torture, and seizures of private property from civilians, barring displaced Syrians from returning to their homes. Ahrar al-Sharqiya constructed and controls a large prison complex outside of Aleppo where hundreds have been executed since 2018. The group has also used this prison to operate an extensive kidnapping for ransom operation targeting prominent business and opposition figures from the provinces of Idlib and Aleppo. Ahrar al-Sharqiya has also integrated former ISIS members into its ranks.

Ahrar al-Sharqiya is being designated pursuant to E.O. 13894 for having engaged in the commission of serious human rights abuse in Syria.

AHMAD IHSAN FAYYAD AL-HAYES AND RAED JASSIM AL-HAYES

Ahmad Ihsan Fayyad al-Hayes (Ahmad al-Hayes), commonly known as “Abu Hatem Shaqra,” is Ahrar al-Sharqiya’s leader and is directly complicit in many of the militia’s human rights abuses. Al-Hayes commanded Ahrar al-Sharqiya’s prison outside of Aleppo, where hundreds of detainees have been executed since 2018. Ahmad al-Hayes has been implicated in the trafficking of Yazidi women and children and has integrated former ISIS members into the ranks of Ahrar al-Sharqiya. A number of former ISIS officials had sworn allegiance to al-Hayes and worked to support Ahrar al-Sharqiya’s ransom and extortion efforts.

Raed Jassim al-Hayes (Raed al-Hayes), commonly known as “Abu Ja’afar Shaqra” and a cousin of Ahmad al-Hayes, has been the military commander of Ahrar al-Sharqiya since late 2017. As a senior figure within the militia, Raed al-Hayes has personally supervised and profited from the militia’s organized theft and sale of equipment from civilian homes and farms. He also commands former ISIS members, including a former member of an ISIS force known for frequent torture of civilians, who is now a heavy weapons official in Ahrar al-Sharqiya.

Ahmad al-Hayes and Raed al-Hayes are being designated pursuant to E.O. 13894 for having acted or purported to act for or on behalf of, directly or indirectly, Ahrar al-Sharqiya.

In conjunction with this action, the U.S. Department of State is sanctioning Saraya al-Areen, a militia affiliated with the Syrian Arab Army, an entity which has been engaged in combat since the beginning of the Syrian conflict, including a 2020 operation in Idlib designed to return that province to regime control. Saraya al-Areen is being designated pursuant to E.O. 13894 for being responsible for or complicit in, or having directly or indirectly engaged in, or attempted to engage in, the obstruction, disruption, or prevention of a ceasefire in northern Syria.

View more information about the State Department’s action here.

HUMANITARIAN ASSISTANCE AND TRADE TO SYRIA

OFAC remains committed to ensuring that U.S. sanctions do not limit the ability of civilians located in Syria to receive humanitarian support from the international community. For information related to the most relevant exemptions, exceptions, and authorizations for humanitarian assistance and trade under the Syria sanctions program and other sanctions programs, please refer to OFAC’s Fact Sheet: Provision of Humanitarian Assistance and Trade to Combat COVID-19. The Fact Sheet also outlines specific guidance for OFAC-administered sanctions programs related to personal protective equipment and other COVID-19-related humanitarian assistance and trade.

For more information regarding the scope of any sanctions programs’ requirements, including the Syria Sanctions Program or the Syria-related Sanctions Program, or the applicability or scope of any humanitarian-related authorizations, please contact OFAC’s Sanction Compliance and Evaluation Division at (800) 540-6322 or (202) 622-2490, or by email at OFAC_Feedback@treasury.gov.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property, and interests in property of the designated persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person or the receipt of any contribution or provision of funds, goods, or services from any such person.

Note: at this time, the link to the State Department action does not work. If it gets corrected, I will post it in a separate post.

Links:

OFAC Notice

Treasury Press Releases: Counter-Terrorism, Syria/Syria-related

Categories: OFAC Updates Sanctions Lists Syrian Sanctions Syrian-related sanctions Terrorism

eric9to5

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