Over the past several years, Syria-based Georgian national Tarkhan Tayumurazovich Batirashvili has held a number of top military positions within ISIL and has led a number of attacks. As of mid-2014, Batirashvili was a senior ISIL commander and Shura Council member located in al-Raqqah, Syria. He was identified as the ISIL military commander in a public video distributed by the group in late June 2014. Batirashvili oversaw an ISIL prison facility in al-Tabqa, close to al-Raqqah, where ISIL possibly held foreign hostages. As of mid-2014, Batirashvili also coordinated closely with ISIL's financial section and had a base of operations for the terrorist organization in the Minbij, Syria area. In addition, Batirashvili publicly acknowledged his role as a senior ISIL military commander in a November 2013 public interview with an unofficial ISIL weekly newspaper. In this interview, he acknowledged arriving in Syria in March 2012, described his reasons for joining ISIL, and outlined his role as the military commander of ISIL responsible for “liberating” certain areas of Syria. He also described five separate military operations he led on behalf of ISIL, including the storming of the Syrian government-controlled Ming Airport. Batirashvili acknowledged that his forces broke into 11 Syrian military installations and seized unidentified spoils from eight of them.
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”).
