Sadoon St, Al-Ani Building, First Floor, Baghdad, Iraq
Official reason
Al-Bashair, directed by Munir Al-Qubaysi, reportedly acted as the largest of Iraq’s arms procurement front companies and was involved in a range of sanctions busting and corruption schemes on behalf of the regime. Al-Bashair reported directly to the Organization of Military Industrialization, which was responsible for Iraq’s military procurement programs and was headed by former Deputy Prime Minister Abd-al-Tawab Mullah Huwaysh. Huwaysh has been named by the U.N. as a senior official of the former Iraq regime on the list established pursuant to UNSCR 1483. Reporting based on documents removed from Al-Bashair’s headquarters describes a variety of deals involving sham contracts, kickbacks, falsified export documentation and money laundering designed to deceive U.N. inspectors and deliver, among other things, missile components, surveillance equipment and tank barrels to the former Iraqi regime. The company also allegedly helped seniors officials of the former regime launder and hide Iraqi government funds.
Executive Order 13315 Executive Order 13315 of August 28, 2003 Blocking Property of the Former Iraqi Regime, Its Senior Officials and Their Family Members, and Taking Certain Other Actions;
Executive Order 13350 of July 29, 2004 Termination of Emergency Declared in Executive Order 12722 With Respect to Iraq and Modification of Executive Order 13290, Executive Order 13303, and Executive Order 13315
Regime
OFAC country specific
Target State
Iraq
Measures
Blocking Property
Official Information
In response to Iraq’s invasion of Kuwait on August 2, 1990, the United States imposed comprehensive sanctions, including a trade embargo against Iraq and a freeze of the assets of the then-Iraqi government, which were implemented in the Iraqi Sanctions Regulations, 31 C.F.R. part 575. Over the years, a series of Executive orders adjusted the sanctions in response to events in Iraq. On September 13, 2010, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published final rules removing the Iraqi Sanctions Regulations from 31 C.F.R. chapter V and adding the Iraq Stabilization and Insurgency Sanctions Regulations, 31 C.F.R. part 576 (“ISISR”), in implementation of Executive Order 13303 of May 22, 2003 (“E.O. 13303”), Executive Order 13315 of August 28, 2003 (“E.O. 13315”), Executive Order 13350 of July 29, 2004 (“E.O. 13350”), Executive Order 13364 of November 29, 2004 (“E.O. 13364”), and Executive Order 13438 of July 17, 2007 (“E.O. 13438”). A summary of the provisions of these Executive orders can be found in the Preamble of the final rule promulgating the ISISR (75 Fed. Reg. 55464, September 13, 2010). The ISISR contain all of the current OFAC restrictions involving Iraq and Iraqi property.
There currently are no broad-based sanctions in place against Iraq, but there are certain prohibitions and asset freezes against specific individuals and entities associated with the former Saddam Hussein regime, as well as parties determined to have committed, or to pose a significant risk of committing, an act of violence that has the purpose or effect of threatening the peace or stability of Iraq or the Government of Iraq or undermining efforts to promote economic reconstruction and political reform in Iraq or to provide humanitarian assistance to the Iraqi people. The Secretary of the Treasury is authorized to name all such individuals and entities. These names are included in OFAC’s list of Specially Designated Nationals and Blocked Persons (“SDN List”). In addition to these targeted sanctions, the ISISR impose some specific prohibitions designed to protect certain Iraqi property and contain certain provisions dealing with residual restrictions from the 1990 Iraqi sanctions.
