Khalil was designated for acting for or on behalf of ANF.
As of early 2016, Khalil was ANF’s third highest-ranking official and appointed as the group’s emir for Syria’s coastal area by ANF emir and Specially Designated Global Terrorist (SDGT) Abu-Muhammad al-Jawlani (al-Jawlani). As a senior ANF official, Khalil took part in discussions among the group’s senior leadership regarding ANF’s overall strategy and the feasibility of establishing an emirate in Idlib, Syria.
For at least two years prior to being appointed emir for Syria’s coastal area, Khalil served as ANF emir of Dar’a, Syria. Under his leadership, he empowered ANF’s security and intelligence operatives responsible for assassinations, ran prisons notorious for torture, and encouraged the looting of vehicles and possessions of Free Syrian Army members.
Khalil was originally sent to Syria with six other individuals in 2011 by former al-Qa’ida in Iraq (AQI) official and current ISIS leader and SDGT Abu Bakr al-Baghdadi to establish what would eventually become ANF. Prior to his involvement with ANF, Khalil joined AQI in the mid-2000s, and remained close to AQI’s former head Abu-Musa’b al-Zarqawi until Zarqawi’s death in 2006.
On June 6, 2003, OFAC issued the Global Terrorism Sanctions Regulations, 31 CFR part 594 (68 FR 34196, June 6, 2003 (“the Regulations”), to implement Executive Order (E.O.) 13224 of September 23, 2001, “Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism” (66 FR 49079, September 25, 2001). OFAC has amended the Regulations on several occasions.
On September 9, 2019, the President, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701–1706) (IEEPA) and the United Nations Participation Act (22 U.S.C. 287c) (UNPA), issued E.O. 13886, “Modernizing Sanctions To Combat Terrorism” (84 FR 48041, September 12, 2019), effective September 10, 2019. In E.O. 13886, the President, finding it necessary to consolidate and enhance sanctions to combat acts of terrorism and threats of terrorism by foreign terrorists, terminated the national emergency declared in E.O. 12947 of January 23, 1995, “Prohibiting Transactions With Terrorists Who Threaten To Disrupt the Middle East Peace Process” (60 FR 5079, January 25, 1995), and revoked E.O. 12947, as amended by E.O. 13099 of August 20, 1998, “Prohibiting Transactions With Terrorists Who Threaten To Disrupt the Middle East Peace Process” (63 FR 45167, August 25, 1998). In addition, the President amended E.O. 13224, in order to build upon initial steps taken in E.O. 12947, to further strengthen and consolidate sanctions to combat the continuing threat posed by international terrorism, and in order to take additional steps to deal with the national emergency declared in E.O. 13224, with respect to the continuing and immediate threat of grave acts of terrorism and threats of terrorism committed by foreign terrorists, which include acts of terrorism that threaten the Middle East peace process.
Section 1 of E.O. 13886 replaces in its entirety section 1 of E.O. 13224, which had been amended by a number of prior Executive orders (E.O. 13224, as amended by all such authorities, is referred to herein as “amended E.O. 13224”), but does not amend the Annex to E.O. 13224, which was previously amended by E.O. 13268 of July 2, 2002, “Termination of Emergency With Respect to the Taliban and Amendment of Executive Order 13224 of September 23, 2001” (67 FR 44751, July 3, 2002) (“amended Annex to E.O. 13224”).
