Specifically, OFAC designated Hayat Ullah Ghulam Muhammad (Haji Hayatullah), Ali Muhammad Abu Turab (Abu Turab), Inayat ur Rahman, and a purported charity managed by Inayat ur Rahman, the Welfare and Development Organization of Jamaat-ud-Dawah for Qur'an and Sunnah (WDO). OFAC designated Ali Muhammad Abu Turab for providing material and financial support to JDQ and Fazeel-A-Tul Shaykh Abu Mohammed Ameen Al-Peshawari, also known as Shaykh Aminullah. Shaykh Aminullah was designated by both the United States and the United Nations (UN) in 2009 for providing material support to al-Qa'ida and LT.
As of 2016, Abu Turab was a JDQ facilitator working to provide thousands of dollars to Pakistan-based JDQ leadership, including Inayat ur Rahman. Also during 2016, Abu Turab facilitated the movement of tens of thousands of dollars from the Gulf to Pakistan. In 2015, Abu Turab supported JDQ leadership by coordinating assistance for Haji Hayatullah and facilitating JDQ's fundraising efforts in the Gulf.
Abu Turab has also regularly facilitated LT's fundraising efforts in the Gulf by introducing LT fundraisers to donors. The donations were used by the Taliban to recruit and train fighters who were sent to fight in Afghanistan. As of 2007, Abu Turab had also facilitated the establishment of LT training camps in collaboration with Abdul Aziz Nuristani, who was designated by OFAC on March 31, 2016 for providing financial, material, or technological support for, or financial and other services to or in support of, al-Qaida, the Taliban, and LT. At least one of the LT camps was used for training on improvised explosive devices, suicide vests manufacturing, and the use of heavy weapons.
Abu Turab has also been involved in the training and facilitation of extremists to Afghanistan. In 2014, Abu Turab facilitated Shaykh Aminullah's travel between Pakistan and the Gulf.
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”).
