EU Court annuls PKK’s 2014-17 sanctions listing

CJEU1The EU General Court has allowed the Kurdistan Workers’ Party’s (PKK) application to annul its 2014 to 2017 terrorism sanctions listings – see judgment: T-316/14. The Court held that the EU had breached its obligation to state reasons because (in summary) a “significant” period of time (over 10 years) had elapsed since the adoption of the material justifying the PKK’s initial designation in 2002, of which was no longer sufficient in determining whether the PKK’s involvement in terrorist activities persisted at the time when the contested acts were adopted between 2014 and 2017.

In 2008, the PKK had successfully challenged its June 2002 terrorism sanctions listing before the EU Court (judgment: T-229/02), on the basis that the EU had again breached its obligation to state reasons.

In March and July 2018, the EU renewed the PKK’s terrorism sanctions listing in Council Implementing Regulation (EU) 2018/468 and Council Implementing Regulation (EU) 2018/1071. Those 2018 re-listings, were not addressed in this judgment so the PKK continues to remain on the EU terrorism sanctions list.

UN, US & EU add 1 person to terrorism sanctions list

TerroristEarlier this week (19 November), the UN Security Council added 1 individual, Hajji ‘Abd al-Nasir, to its ISIL (Da’esh) and Al-Qaida sanctions list (UN asset freeze, travel ban and arms embargo imposed). See UN Press Release and Narrative Summary of Reasons for Listing.

Yesterday (20 November), the US implemented this UN listing by designating al-Nasir as a Specially Designated Global Terrorist (SDGT) pursuant to Executive Order 13224. See OFAC Notice and US Department of State Press Release.

On 22 November, the EU implemented this UN listing, see Commission Implementing Regulation (EU) 2018/1809.

US sanctions Russia-Iran oil network supporting Syrian regime & terrorist groups

US Treasury Building2OFAC has designated 5 individuals and 4 entities of an “international network through which the Iranian regime, working with Russian companies, provides millions of barrels of oil to the Syrian government. The Assad regime, in turn, facilitates the movement of hundreds of millions of U.S. dollars (USD) to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) for onward transfer to HAMAS and Hizballah.” The designations were made pursuant to Syria-related Executive Order 13582 and/or terrorism-related Executive Order 13224 (both authorities impose US asset freezes). See OFAC Notice, US Treasury Press Release, Department of State Press Release, and OFAC Advisory: Sanctions Risks Related to Shipping Petroleum to Syria.

The 5 individuals: Muhammad Qasim al-Bazzal; Mohamed Amer Alchwiki; Andrey Dogaev; Rasoul Sajjad; and Hossein Yaghoubi Miab.

The 4 entities: Global Vision Group (Russia-based); Promsyrioimport (Russia-based); Tadbir Kish Medical and Pharmaceutical Company (Iran-based); and MB Bank (Russia-based).

US sanctions 6 as Specially Designated Global Terrorists

Logo_of_the_U.S._Office_of_Foreign_Assets_Control_(OFAC)OFAC has designated 4 Hizballah-affiliated individuals as Specially Designated Global Terrorists (SDGTs), pursuant to Executive Order 13224, for “lead[ing] and coordinat[ing] the group’s operational, intelligence, and financial activities in Iraq” (US asset freezes imposed). The 4 individuals – who are also subject to secondary sanctions under the Hizballah Financial Sanctions Regulations – are: Shibl Muhsin ‘Ubayd Al-Zaydi; Yusuf Hashim; Adnan Hussein Kawtharani; and Muhammad ‘Abd-Al-Hadi Farhat. These designations follow the signing into law (on 25 October 2018) of the Hizballah International Financing Prevention Amendments Act of 2018 (see previous blog). See OFAC Notice and US Treasury press release.

The US Department of State has also designated a Hizballah-linked individual, Jawad Nasrallah, and a Palestine and Egypt-based entity, Al-Mujahidin Brigades, as SDGTs under Executive Order 13224 (US asset freezes). See the unpublished Federal Register Notices here and here.

OFAC releases 2017 Terrorist Assets Report

OFAC3OFAC has published its 2017 Terrorist Assets Report outlining the “nature and extent of assets held in the United States by terrorism-supporting countries and organizations engaged in international terrorism”.

The Report states that sanctions targeting international terrorist organisations had resulted in the blocking of approximately $44 million in the US in 2017 ($34 million in 2016). Whereas, approximately $202 million in assets relating to the four designated state sponsors of terrorism in 2017 (Iran, Sudan, Syria and North Korea) had been blocked ($149 million in 2016).

US Senate passes 2 Hizballah sanctions Bills


This month, the US Senate passed 2 Bills targeting Hizballah: 

1.      The Hizballah International Financing Prevention Amendments Act of 2018 amends its 2015 legislation to impose sanctions on: (i) foreign persons that knowingly assist in, or provide support for, fundraising or recruitment activities for Hizballah; (ii) agencies of foreign governments that provide Hizballah with financial support, arms or other assistance; and (iii) Hizballah networks, by reason of its narcotics trafficking and significant transnational criminal activities.

2.      The Sanctioning the Use of Civilians as Defenseless Shields Act imposes sanctions (asset freeze and travel restrictions) on each foreign individual and entity that is a member of, or acts on behalf of, Hizballah and that is responsible for, or complicit in, the use of human shields, as well as each foreign person, entity, or instrumentality of a foreign state that has supported or facilitated such person or entity.

Both Bills will become law once signed by President Donald Trump.

Update: On 25 October 2018, President Donald Trump signed the Hizballah International Financing Prevention Amendments Act of 2018 into law. See White House press release.

USA & Gulf States sanction Taliban facilitators & Iranian supporters

Terrorist.jpgToday, the 7-member nations* of the Terrorist Financing and Targeting Center (TFTC) sanctioned 8 individuals “associated with the Taliban, including those facilitating Iranian support to bolster the terrorist group”.

OFAC designated the following as Specially Designated Global Terrorists, pursuant to Executive Order 13224 (asset freezes imposed): Mohammad Ebrahim Owhadi; Esma’il Razavi; Abdullah Samad Faroqui; Mohammad Daoud Muzzamil; Abdul Rahim Manan; Abdul Aziz; Sadr Ibrahim; and Hafiz Abdul Majid.

TFTC member states also designated Naim Barich for “managing the Taliban’s relationship with Iran”. The US previously designated Naim Barich under the US Kingpin Act in November 2012. See OFAC Notice and US Treasury press release.

*(1) Bahrain; (2) Kuwait; (3) Oman; (4) Qatar; (5) Saudi Arabia; (6) UAE; and (7) USA

OFAC sanctions Iraqi money services business over ISIS support

US Treasury Building2OFAC 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.