The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action today to disrupt Lashkar-e Tayyiba’s (LeT) fundraising and support networks by designating two of the group’s senior leaders, Muhammad Sarwar (Sarwar) and Shahid Mahmood (Mahmood), as Specially Designated Global Terrorists (SDGTs) pursuant to Executive Order (E.O.) 13224. Sarwar and Mahmood are being designated for acting for or on behalf of LeT, a terrorist organization based in Pakistan. Muhammad Sarwar has been a senior LeT official in Lahore for over ten years and has held various leadership roles in the group, including his current position as LeT’s emir for Lahore, Pakistan, a position he has held since at least January 2015. As the LeT emir of Lahore, Sarwar maintains relationships with LeT’s most senior leaders. Between 2012 and 2013, Sarwar worked with LeT’s foreign affairs chief Hafiz Abdul Rahman Makki, and in early 2013, Makki asked Sarwar for money to pay for his travel within Pakistan. OFAC designated Makki pursuant to E.O. 13224 in November 2010. Sarwar’s activity with LeT dates back to the early 2000s.
In his capacity as LeT Lahore emir, Sarwar has been directly involved in LeT fundraising activities and uses the formal financial system in Pakistan to raise and move funds on behalf of LeT. For example, in 2008, Sarwar led delegations of businessmen to LeT facilities for the purpose of soliciting donations for the group, and as of mid-2009, Sarwar was one of two officials who headed LeT’s finance wing in Lahore.
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”).
