OFAC Targets Top Syrian Officials

Today the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) designated three (3) Syrian Government Officials for sanctions pursuant to Executive Order 13573 (E.O. 13573). The Syrian officials designated include Syria’s Foreign and Expatriates Minister Walid Al-Moallem, Syria’s Presidential Political and Media Advisor Bouthaina Shaaban and Syria’s Ambassador to Lebanon Ali Abdul Karim Ali.

Walid Al-Moallem was appointed Foreign and Expatriates Minister in February 2006 and Bouthaina Shaaban has served as Syria’s Presidential Political and Media Advisor since July 2008. As Syria’s primary link to Lebanon, Ali Abdul Karim Ali has served as the Syrian Ambassador to Lebanon since May 2009 and has maintained close ties to Syrian intelligence throughout his diplomatic career.

U.S. persons are prohibited from engaging in transactions with any of these individuals and/or any other person or entity targeted by E.O. 13573 or any other sanctions program. Moreover, any assets these individuals held which were under the jurisdiction of the United States at the time of the designation will be frozen. It would be surprising, however, if any of these individuals still maintained assets under U.S. jurisdiction considering that Syria sanctions targeting the Government of Syria went into effect on May 18, 2011; over three (3) months ago. Surely, they must have foreseen the possibility of a future designation for their ties to the Assad government.

While not completely shocked, I am a little surprised that the press release regarding the designation did not provide more information on the reasons for the designation. Generally speaking, Treasury provides some information in their press releases regarding the activities of the designated parties. In this press release they did not offer much information outside of the positions these individuals held in the Assad regime. It would be interesting to see what led to these parties being designated. Also, such information could provide insight into whether this set of designations portends further designations of Syrian officials.

Those designated under OFAC administered sanctions can request a request consideration of their designation pursuant to 31 C.F.R. 501.807 and can obtain legal counsel in the U.S. to assist in the process. However, any compensation for such services made in regards to such representation must be specifically licensed by OFAC.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com.

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