Specifically, OFAC designated Shibl Muhsin ‘Ubayd Al-Zaydi, Yusuf Hashim, Adnan Hussein Kawtharani, and Muhammad ‘Abd-Al-Hadi Farhat as Specially Designated Global Terrorists (SDGTs) pursuant to Executive Order (E.O.) 13224, which targets terrorists and those providing support to terrorists or acts of terrorism. Al-Zaydi was designated for acting for or on behalf of the Islamic Revolutionary Guard Corps–Qods Force (IRGC-QF), and assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Hizballah.
Al-Zaydi has served as a financial coordinator between the IRGC-QF and sectarian armed groups in Iraq and assisted in facilitating Iraqi investments on behalf of IRGC-QF Commander Qasem Soleimani, whom OFAC designated on October 11, 2011, for acting for or on behalf of the IRGC-QF. Al-Zaydi has also coordinated the smuggling of oil from Iran on behalf of Iran, the smuggling of oil into Syria on behalf of Iran, and has sent Iraqi fighters to Syria allegedly at the IRGC-QF’s request. Al-Zaydi has appeared publically with IRGC-QF Commander Qasem Soleimani at least four times (see photos below).
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”).
