On September 30, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three Syrian individuals and 13 entities, placing them on the Specially Designated Nationals and Blocked Persons (SDN) List. These persons and entities are associated with the Fourth Division of the Syrian Arab Army, the Syrian General Intelligence Directorate and the Central Bank of Syria.
Specifically, OFAC added the following individuals, among others, to the SDN List: (1) Khodr Taher Bin Ali (Taher), a Syrian businessman who serves as an intermediary and contractor for the Fourth Division of the Syrian Arab Army, and his business network; (2) Husam Muhammad Louka, the current head of the Syrian General Intelligence Directorate (GID); and (3) Hazem Younes Karfoul, governor of the Central Bank of Syria. Further details on these individuals and Taher’s business entities are available here.
OFAC has also issued Syria General License 20, “Authorizing Transactions and Activities Necessary for Wind Down of Transactions with Emma Tel LLC,” one of the entities that was also added to the SDN List. All transactions and activities that are ordinarily incident and necessary to the wind-down of transactions involving, directly or indirectly, Emma Tel LLC, or any entity in which Emma Tel LLC owns, directly or indirectly, a 50 percent or greater interest, are authorized through December 30, 2020 only.
As a result of these persons and entities being placed on the SDN List, all property and interests in property of these persons or entities that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. In addition, non-U.S. persons that engage in certain transactions with the persons and entities designated on the SDN List also risk designation.