Abd al-Rahman Abd al-Nabi Shams (Shams), Yahya Muhammad al-Abd-al-Muhsin (Abd-al-Muhsin), Majdi Fa’iz al-Ustadz (Ustadz), and Sulaiman al-Banai are being designated as SDGTs pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Ali al-Banai.
As of 2019, Shams, Ali al-Banai’s Bahrain-based nephew, coordinated the development of two real estate projects in Bahrain and the delivery of funds to Gulf-based individuals on behalf of Ali al-Banai. As of 2019, Ali al-Banai had transferred millions of Qatari riyals to an account held by Shams. Concurrent with this action, the Government of Bahrain has frozen the bank accounts of this individual and has additionally referred three individuals to their prosecutor’s office.
As of 2019, Abd-al-Muhsin, a Saudi Arabia-based relative of Lari, managed Ali al-Banai’s real estate throughout the Gulf, including Bahrain, Saudi Arabia, and the United Arab Emirates (UAE), and was tasked by Ali al-Banai to manage Lari’s businesses in the UAE. Abd-al-Muhsin also maintained power of attorney for Banai’s properties in Bahrain. As of 2018, Abd-al-Musin maintained regular contact with both Ali al-Banai and Lari and made regular trips to Qatar to meet with Ali al-Banai. As of 2019, Ali al-Banai had transferred hundreds of thousands of Qatari riyals to Abd-al-Muhsin. As of 2019, Ustadz coordinated Ali al-Banai’s commercial activities in Qatar. Ustadz owned properties on behalf of Ali al-Banai, which Ali al-Banai used as collateral to obtain loans to fund investments in Turkey. Ustadz also oversaw financial matters for Ali al-Banai.
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”).
