OFAC has designated Afaq Dubai, an Iraq-based money services business (MSB), as a Specially Designated Global Terrorist pursuant to Executive Order 13224 (US asset freeze) for “moving money for [ISIS]”. The US Treasury press release says “[c]ontrary to what the name may imply, this MSB is located in Iraq and does not have any branches in the United Arab Emirates”. See OFAC Notice.
Yesterday, the UN Security Council announced that it has added British national Anjem Choudary to its ISIL (Da’esh) & Al-Qaida sanctions list for “recruiting for” and “otherwise supporting acts or activities of” ISIL (asset freeze, travel ban, and arms embargo imposed). The UN Narrative Summary of Reasons for Listing notes that Mr Choudary was sentenced in the UK (September 2016) for inviting support for ISIL, and that since his conviction and imprisonment, he has not made any statements denouncing his allegiance to and support for ISIL.
On 18 October 2018, the EU implemented this UN listing, see Commission Implementing Regulation (EU) 2018/1562.
Yesterday, the EU extended its ISIL (Da’esh) and Al-Qaida sanctions measures until 31 October 2019. The EU also added Algerian national Hocine Bouguetof to the sanctions list (travel ban, asset freeze, and arms embargo imposed). See Council Decision (CFSP) 2018/1540 and Council Implementing Regulation (EU) 2018/1539.
Max Hill QC, the UK Independent Reviewer of Terrorism Legislation, has published his final annual report (10 October) on the operation of the Terrorism Acts in 2017. It covers proscribed organisations (5 organisations were proscribed in 2017) and the replacement of the current Terrorist Asset Freezing Act 2010 with the Sanctions and Anti-Money Laundering Act 2018 for terrorist asset freezing in the UK. The report also makes a number of recommendations on TPIMs and port and border controls.
Yesterday, OFSI renewed the terrorist listings of two entities – Ejército de Liberación Nacional (ELN) and Sendero Luminoso (SL) – under the Terrorist Asset-Freezing etc Act 2010 (TAFA).
The OFSI Notice explains that a renewed designation may be appealed to the High Court (or, in Scotland, to the Court of Session) under section 26 of TAFA.
Yesterday (4 October), the UN Security Council added Jama’a Nusrat ul-Islam wa al-Muslimin (JNIM) to its ISIL (Da’esh) and Al-Qaida sanctions list. According to the UN summary of reasons for listing, JNIM has “described itself as the official branch of Al-Qaida in Mali”. It will now be subject to a UN asset freeze and arms embargo. See UN press release.
On 5 September 2018, the US imposed an asset freeze on JNIM by designating it as a Foreign Terrorist Organisation and as a Specially Designated Global Terrorist (see previous blog).
On 8 October 2018, the EU implemented the UN listing of JNIM, see Commission Implementing Regulation (EU) 2018/1494.
Today, OFAC has designated Lebanese national Muhammad ‘Abdallah al-Amin as a Specially Designated Global Terrorist (SDGT), pursuant to Executive Order 13224, for “providing material support to Hizballah insider and financier Adham Husayn Tabaja”. OFAC has also designated 7 Lebanon-based companies owned or controlled by him: Sierra Gas SAL Offshore; Lama Foods SARL; Lama Foods International Offshore SAL; Impulse SARL; Impulse International SAL Offshore; M. Marine SAL Offshore; and Thaingui SAL Offshore. As a result, all are now subject to US asset freezes. See OFAC Notice and US Treasury press release.
Last week (19 September), OFAC designated two ISIS financiers, pursuant to Executive Order 13224 (asset freezes imposed).
Syria-based Emraan Ali was designated for “acting for or on behalf of ISIS”, and Trinidad-based Eddie Aleong was designated for “assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of ISIS”. See OFAC Notice and US Treasury press release.