US indicts 3 men for violating Iran sanctions in connection with $9bn military supply contracts

US Department of JusticeThe US Department of Justice has announced that three US-based men, Abul Huda Farouki, Mazen Farouki, and Salah Maarouf, have been indicted for (inter alia) violating US-Iran sanctions in connection with two multi-million-dollar contracts ($8bn and $984m) to provide supplies and logistical support to US troops in Afghanistan (awarded by the US Department of Defence). The contracts required the defendants to abide by US-Iran sanctions, which prohibit US citizens and companies from engaging in commercial activity in Iran. However, according to the indictment, the defendants conspired to cut costs under the contracts by shipping materials and trucks to Afghanistan via Iran, rather than using legal but more expensive routes. Last week (29 November), all three defendants pleaded not guilty on arraignment. The next hearing is scheduled for 6 December.

EU implements UN amendment to Afghanistan listing

EU CommissionEarlier this month, the UN Security Council amended the listing of Mohammed Omar Ghulam Nabi under its Afghanistan sanctions by altering his UN designation date from 31 January 2001 to 12 April 2000. UN press release here.

Today, the EU has implemented that UN amendment by adopting Council Implementing Decision (CFSP) 2018/656 and Council Implementing Regulation (EU) 2018/648.

EU updates Syria, Afghanistan, Yemen & Terrorism sanctions


The EU has de-listed Hisham Ikhtiyar and Anisa Al-Assad from its sanctions on Syria, and deleted a duplicate entry for Major General Fahd (aka. Lt General Fahid).  See Regulation 2016/1735 implementing Regulation 36/2012 and Decision 2016/1746 implementing Decision 2013/255/CFSP.


The EU has amended the list of people and entities under its sanctions on Afghanistan, in accordance with UN updates to its sanctions list on 21 July and 7 September.  See Regulation 2016/1736 implementing Regulation 753/2011 and Decision 2016/1748 implementing Decision 2011/486/CFSP.


The EU has updated the identifying information for Abd Al-Houthi and Abdulmalik al-Houthi under its sanctions on Yemen.  The action implements UN updates made on 26 August 2016.  See Regulation 2016/1737 implementing Regulation 1352/2014 and Decision 2016/1747 implementing Decision 2014/932/CFSP.


The EU has de-listed Muhammad Abu-Al-Khayr and Hassan Abu Bakr Qayed from its sanctions on ISIL and Al-Qaida.  The de-listings implement a UN decision to remove the 2 people from its sanctions on 24 September 2016.  See Commission Implementing Regulation 2016/1739 amending Council Regulation 881/2002.

EU Afghanistan, Somalia and Tunisia listing updates

In order to implement decisions by the UN Security Council to amend its sanctions listings, the EU has added Torek Agha to its Afghanistan list and deleted Ali Ahmed Nur Jim’ale from its Somalia list.

The US sanctioned Torek Agha in October for being “a long-standing Taliban member”, who had “been central to spearheading brutal military attacks and raising millions of dollars to support the Taliban’s ruthless acts of terrorism” (see previous blog), allegations echoed by the UN in its reasons.  Ali Ahmed Nur Jim’ale was said by the UN to have supported al-Shabaab, listed itself for threatening the peace, security, or stability of Somalia.  HM Treasury’s notice is here.

The Afghanistan update is made by Council Implementing Regulation (EU) 2015/2043 implementing Council Regulation 753/2011 and Council Implementing Decision (CFSP) 2015/2054 implementing Council Decision 2011/486/CFSP.  The Somalia update is made by Council Implementing Regulation (EU) 2015/2044 implementing Council Regulation 356/2010 and Council Implementing Decision (CFSP) 2015/2053 implementing Council Decision 2010/231/CFSP. The UN’s press releases on the Afghanistan and Somalia updates are here and here.

The EU has also published a notice for the attention of people and entities listed in its Tunisia sanctions, informing them that, following a review, the Council has concluded that they should all remain on the list of those designated, and that they may request reconsideration of that decision and present observations to the Council before 1 December 2015.


The EU has updated its Afghanistan, Libya, Belarus, and Counter-Terrorism sanctions regimes.


The EU’s Afghanistan sanctions target people associated with the Taliban and who constitute a threat to the peace, stability, or security of the country. The EU has added Abdul Basir Noorzai and the entity Haji Basir and Zarjmil Company Hawala to its listings, and deleted the entry of Sangeen Zadran Sher Mohammad.

The update is made by Council Implementing Regulation (EU) 2015/1322 implementing Council Regulation (EU) 753/2011 and Council Implementing Decision (CFSP) 2015/1332 implementing Council Decision 2011/486/CFSP. HM Treasury’s notice is here. The EU’s notices to listed persons are here and here.


The EU has updated the identifying information for 20 people and 16 entities listed under its sanctions regime on Libya, by Council Implementing Regulation (EU) 2015/1323 implementing Council Regulation 204/2011. It has also consolidated the restrictive measures imposed by Council Decision 2011/137/CFSP, as amended by subsequent Decisions, into Council Decision (CFSP) 2015/1333 and repealed the former Decision. HM Treasury’s notice is here.

In addition, the EU has added a new exception to its arms embargo on Libya for military equipment that will not be used for internal repression and is solely intended for security or disarmament assistance to the Libyan government, as approved by the UN sanctions committee on Libya. Further, it has made other minor changes to the wording of the Regulation. The changes are made by Council Regulation (EU) 2015/1324 amending Council Regulation (EU) 204/2011.

The EU’s notices to listed persons are here and here.


24 people have been removed from the EU’s Belarus sanctions listings. The deletions are made by Council Implementing Decision (CFSP) 2015/1335 implementing Council Decision 2012/642/CFSP. HM Treasury’s notice is here.


In accordance with a decision by the Sanctions Committee of the UN Security Council, the EU has removed Aliaskhab Alibulatovich Kebekov from its Al Qaida sanctions listings and added two aliases for listed person Mohammed Al Ghabra. The changes are made by Commission Implementing Regulation (EU) 2015/1330 amending Council Regulation (EC) 881/2002. HM Treasury’s notice is here.

The EU has also reviewed its Counter-Terrorism listings under Common Position 2001/931/CFSP, as it is required to do at regular intervals, and decided that all 10 listed people and 23 entities should continue to be subject to the restrictive measures provided for therein. The extension is set out in Council Implementing Regulation (EU) 2015/1325 implementing Council Regulation (EC) 2580/2001 and repealing Council Implementing Regulation (EU) 2015/513 and Council Decision (CFSP) 2015/1334 updating the list of persons subject to Common Position 2001/931/CFSP and repealing Council Decision (CFSP) 2015/521. The EU’s notice to listed persons is here.


The European Union has published Implementing Regulation No 1057/2014 and Implementing Decision 2014/701/CFSP which implement the updates made by the United Nations Security Council to its sanctions relating to Afghanistan. The amendments add 5 new people (Qari Rahmat, Qari Saifullah Tokhi, Yahya Haqqani, Saidullah Jan and Muhammad Omar Zadran), all on the basis that they are senior members of the Taliban or the Haqqini Network), and amend the identifying information for 14 people already listed. The new Regulation amends Regulation No 753/2011.

The UN has imposed restrictive measures on the Taliban and its associates since 2011.  Interestingly, in the light of the Kadi litigation in the European Courts (see previous blog), all EU listings which implement the UN list now include information from the narrative summary of reasons provided by the United Nations Sanctions Committee.

A Notice in the Official Journal informs listed people of the possibility of challenging the decision in the General Court of the EU or submitting a request to the United Nations Focal Point or Council of the EU for reconsideration.  A list of all EU sanctions in force against Afghanistan is on the ‘sanctions in force’ section of this blog.


On 1 February 2013, Council Regulation (EU) No 86/2013 of 31 January 2013 came into force. This amended the Annex to Council Regulation (EU) No 753/2011, concerning restrictive measures directed against certain individuals, groups, undertakings and entities in view of the situation in Afghanistan.

The amendment to the Annex reflected decisions made on 28 December 2012, and 15 January 2013, by the United Nations Security Council Sanctions Committee, to remove the names of three individuals from the list of persons made subject to targeted sanctions. The entry for a fourth person, Badruddin Haqqani (alias Atiqullah), was amended to reflect further information made available to the UN Sanctions Committee.