OFAC designated Abdurrahman Ado Musa, Salihu Yusuf Adamu, Bashir Ali Yusuf, Muhammed Ibrahim Isa, Ibrahim Ali Alhassan, and Surajo Abubakar Muhammad pursuant to Executive Order (E.O.) 13224, as amended, which targets terrorists, leaders, and officials of terrorist groups, and those providing support to terrorists or acts of terrorism. The U.S. Department of State designated Boko Haram as a Foreign Terrorist Organization and a Specially Designated Global Terrorist on November 14, 2013. The UAE Federal Court of Appeals in Abu Dhabi convicted Abdurrahman Ado Musa, Salihu Yusuf Adamu, Bashir Ali Yusuf, Muhammed Ibrahim Isa, Ibrahim Ali Alhassan, and Surajo Abubakar Muhammad for transferring $782,000 from Dubai to Boko Haram in Nigeria. Salihu Yusuf Adamu and Surajo Abubakar Muhammad were sentenced to life imprisonment for violations of UAE anti-terrorism laws; Abdurrahman Ado Musa, Bashir Ali Yusuf, Muhammed Ibrahim Isa, and Ibrahim Ali Alhassan were sentenced to 10 years in prison, followed by deportation. Today’s designations will prevent these individuals’ funds from being used further to support terrorism.
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”).
