Umar Talib Zughayr al-Rawi (Umar) was designated for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to, or in support of, ISIS.
As of early October 2017, Umar owned several companies in Iraq, Syria, and Turkey and was in charge of performing transactions for ISIS in those countries. Umar’s main hawala was located in the vicinity of al-Qa’im, Anbar Province, Iraq.
As of late 2017, ISIS financial facilitator Abd-al-Rahman al-Rawi, also designated today, and his business partner and cousin, Umar, had been selected to manage financial affairs for ISIS’s so-called Wilayah al-Furat following the death of Fawaz al-Rawi. Abd-al-Rahman and Umar had been partners in a currency exchange company in al-Qa'im, Anbar Province, Iraq with Fawaz al-Rawi. Both Abd-al-Rahman and Umar had formally accepted their appointments. Umar was responsible for money transfers inside Iraq. In addition to dealing with large sums of money arriving from abroad and distributing the funds to ISIS’s Iraqi and Syrian provinces, Umar and Abd-al-Rahman also distributed Iraqi retirees’ salaries from the GOI via an electronic payment system. Umar and Abd-al-Rahman also transferred funds to Iraq to purchase vehicles for ISIS fighters and exchanged cash for ISIS coinage.
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”).
