Wael Bazzi was designated for acting for or on behalf of Mohammad Bazzi.
Since his designation in May 2018, Mohammad Bazzi has turned to his son, Wael Bazzi, to continue doing business in the Gambia. Mohammad Bazzi has been able to conduct business through Wael Bazzi, upon whom he has continued to rely on to register new businesses and bid on Gambian government contracts. Wael Bazzi formed a petroleum company to maintain his father’s access to the oil industry. Additionally, Mohammad Bazzi coordinated with Wael Bazzi and a Belgium-based GTG employee to change GTG’s name after GTG’s designation. Wael Bazzi was the purported owner of this new company, likely to obscure Mohammad Bazzi’s involvement and circumvent Mohammad Bazzi‘s designation.
Wael Bazzi has helped Mohammad Bazzi and a Lebanon-based associate facilitate payments for a business contract. Additionally, Wael Bazzi likely established an account for Voltra Transcor Energy, in connection with Mohammad Bazzi’s attempted use of an intermediary company to move money to GTG and circumvent OFAC sanctions. In 2017, Mohammad Bazzi planned to submit his son, Wael Bazzi, to fill the Lebanese Consular position in the Gambia because he could exert his influence over Wael. As of at least early 2018, Wael Bazzi has been witting of Mohammad Bazzi’s involvement in illicit activity.
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”).
