On 15 July 2020, the U.S. and Gulf Cooperation Council (“GCC”)-led Terrorist Financing Targeting Center (“TFTC”) designated six targets affiliated with the Islamic State of Iraq and Syria (“ISIS”), including an entity allegedly posing as a charity (and its director) based in Afghanistan that allegedly provided support to ISIS’ branch in that country, ISIS-Khorasan (“ISIS-K”). The entities that were designated are: Al Haram ExchangeTawasul CompanyAl-Khalidi ExchangeNejaat Social Welfare Organization Five of these targets (which includes…
The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently designated as Specially Designated Nationals (“SDNs”) a number of entities linked to the Iranian steel, aluminum, and iron sectors that are likely to be of particular interest for companies doing trade in or with the Middle East or financial institutions financing trade and business in the region. This post highlights OFAC’s recent action and outlines some practical considerations. On 25 June 2020,…
On June 3, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new Syria-Related Sanctions Regulations (the “Regulations”), effective June 5, 2020, to implement Executive Order 13894 (“EO 13894”) issued by the President on October 14, 2019 in light of Turkey’s military actions in Syria. The Regulations are a codification of EO 13894 and do not represent new sanctions against Syria. They are also separate from US comprehensive sanctions targeting Syria under…
On 19 March 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned five companies based in the United Arab Emirates (“UAE”), pursuant to Executive Order 13846 (“EO 13846”), for their alleged involvement in purchasing hundreds of thousands of metric tons of petroleum products from the National Iranian Oil Company (“NIOC”) for delivery to the UAE. The following UAE-based companies were added to the US Specially Designated Nationals and Blocked Persons List (“SDN List”):…