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. Shahid Mahmood has been a longstanding senior LeT member based in Karachi, Pakistan, and has been affiliated with the group since at least 2007. As early as June 2015 through at least June 2016, Mahmood served as the vice chairman of Falah-i-Insaniat Foundation (FIF), a humanitarian and fundraising arm of LeT. FIF has been designated as an alias for LeT pursuant to E.O. 13224 and the State Department’s Foreign Terrorism Organization authorities, as well as by the UN 1267/1989 Committee. In 2014, Mahmood was the leader of FIF in Karachi. In August 2013, Mahmood was identified as a LeT publications wing member.
Since at least 2012, Mahmood has routinely traveled overseas and worked with international organizations on behalf of LeT to conduct business for the group in FIF’s name. For example, when acting as the head of FIF in Karachi, Mahmood traveled to Bangladesh to distribute funds to a Burmese migrant camp for the purpose of facilitating LeT recruitment. In August 2012, Mahmood, while in charge of the Sindh, Pakistan chapter of FIF, led a LeT delegation to Burma, and in mid-2014, he traveled to Syria and Turkey and was subsequently appointed to lead FIF efforts in both countries. Mahmood has also traveled to Bangladesh and Gaza on behalf of FIF.
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”).
