Skip to main content
Menu Icon Menu Icon

InfoBytes Blog

Financial Services Law Insights and Observations

OFAC sanctions Syrian financial facilitators allied with IRGC-QF

Financial Crimes Of Interest to Non-US Persons Department of Treasury OFAC OFAC Designations OFAC Sanctions SDN List Syria

Financial Crimes

On May 30, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 13582 and the Caesar Syrian Civilian Protection Act of 2019 (Caesar Act), against two Syrian money service businesses and the three owners and operators of Al-Fadel Exchange, which have secretly helped the Syrian regime under Bashar al-Assad and its Hizballah and Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) allies maintain access to the international financial system in violation of international sanctions. Both E.O. 13582 and the Caesar Act underscore the gravity of enabling violent regimes to circumvent sanctions. These sanctions come on the heels of OFAC’s March 28 designation, also pursuant of the Caesar Act, of individuals involved in Syria’s drug production and trafficking (previously covered by InfoBytes here). As a result of these sanctions, “all property and interests in property of these persons which are in or come within the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” U.S. persons are also generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. Additionally, “persons that engage in certain transactions with the persons designated today may themselves be exposed to sanctions or subject to an enforcement action.”