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3/19/2020

Treasury Targets Wide Range of Terrorists and Their Supporters Using Enhanced Counterterrorism Sanctions Authorities | U.S. Departm…

Treasury Targets Wide Range of Terrorists and Their Supporters
Using Enhanced Counterterrorism Sanctions Authorities
September 10, 2019

President Trump’s Updated E.O. 13224 Provides New Tools to Deter Evolving Threats
Washington – Today, the U.S. Department of the Treasury’s O ice of Foreign Assets Control
(OFAC) utilized newly enhanced counterterrorism sanctions authorities to designate a series of
terrorist leaders, facilitators, and entities. Equipped with new tools from President Trump’s
recently updated Executive Order (E.O.) 13224, which became e ective today, Treasury
designated 15 leaders, individuals, and entities a iliated with terror groups. Today’s action
targets a wide array of groups, including entities a iliated with HAMAS, the Islamic State of Iraq
and Syria (ISIS), al-Qa’ida, and the Islamic Revolutionary Guard Corps Qods-Force (IRGC-QF),
and combined with actions taken by the State Department amounts to some of the furthest
reaching designations of terrorists and their supporters in the past 15 years.
“Since the horrific attacks of 9/11, the U.S. government has refocused its counterterrorism
e orts to constantly adapt to emerging threats. President Trump’s modernized
counterterrorism Executive Order enhances the authorities we use to target the finances of
terror groups and their leaders to ensure they are as robust as possible,” said Secretary Steven T.
Mnuchin. “These new authorities will allow the U.S. Government to starve terrorists of
resources they need to attack the United States and our allies, and will hold foreign financial
institutions who continue to do business with them accountable. These new tools aid our
unrelenting e orts to cut o terrorists from their sources of support and deprive them of the
funds required to carry out their destructive activities. They serve as a powerful deterrent to
radical terror groups and those seeking to aid their nefarious goals.”

HISTORY OF POST-9/11 TERRORISM AUTHORITIES
Twelve days a er the attacks of September 11, 2001, the President signed the original E.O.
13224 to disrupt the financial infrastructure of terrorist groups worldwide. Since then, this
authority has become a cornerstone of Treasury’s e orts to prevent terrorist attacks by cutting
o sources of funding and denying access to the international financial system. Yet terrorists
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and their supporters are constantly seeking to test and evade our counterterrorism measures.
As the U.S. Government confronts evolving threats of worldwide terrorism, the President has
significantly enhanced E.O. 13224 to strengthen the U.S. Government’s ability to disrupt terrorist
activity by depriving terrorist supporters of financial, material, and logistical backing worldwide
The U.S. Government has leveraged E.O. 13224 to dismantle networks supporting a broad range
of terrorist groups from al-Qa’ida and ISIS to Iranian-backed groups like Hizballah and HAMAS.
E.O. 13224 also serves as an important tool in our e orts to drain the financial resources of the
Iranian regime’s malign actors including the IRGC, and its foreign expeditionary arm, the Qods
Force (IRGC-QF).

ENHANCED E.O. 13224 PROVIDES NEW
COUNTERTERRORISM TOOLS
E.O. 13224, as amended, provides the Treasury and State Departments with new tools that allow
the U.S. Government to better identify and designate perpetrators of terrorism worldwide.
Specifically, the E.O.:
Contains new designation criteria that allows the U.S. Government to more e iciently target
leaders or o icials of terrorists groups as well as individuals who participate in terrorist
training;
Provides for secondary sanctions against foreign financial institutions that have knowingly
conducted or facilitated significant financial transactions on behalf of any person
sanctioned pursuant to E.O. 13224;
Authorizes Treasury to prohibit a foreign financial institution that has knowingly conducted
or facilitated a significant transaction with any Specially Designated Global Terrorist (SDGT)
from opening or maintaining a correspondent or payable-through account in the United
States;
Consolidates U.S. counterterrorism authorities under a single sanctions program by
eliminating E.O. 12947 and combining that authority’s goal of defending the Middle East
Peace Process with E.O. 13224’s global remit and expanded authorities.
This new authority serves to put all foreign financial institutions on notice that enabling
terrorists and their financial backers to rely upon the international financial system to facilitate
their malign activities will have consequences. This Administration remains committed to
facilitating the peace process in the Middle East and will use this amended authority to sanction
those who stand in the way of progress.
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ENHANCED AUTHORITIES ALLOW TREASURY TO TARGET
BROADER RANGE OF TERRORISTS AND ACTIVITIES
These new authorities allow Treasury to target a broad range of new terrorist leaders,
supporters, entities, and activities. Below are the terrorists and sympathizers targeted today
under these new authorities:

Muhammad Sa’id Izadi (Izadi)
Izadi is a leader or o icial of the IRGC-QF.
Lebanon-based Izadi is the chief of the Palestinian O ice of the IRGCQF Lebanon Corp.
Izadi has materially assisted, sponsored, or provided financial, material, or technological
support for, or goods or services to, HAMAS.
As of late 2016, Izadi required a HAMAS Political O icer member to get permission from three
senior HAMAS leaders in order to receive money directly from him. The HAMAS Political O ice
member stated Izadi would be sending $1 million dollars in addition to Izadi’s regular allocation,
and an additional $1 million dollars earmarked for the HAMAS Political O ice member.

Zaher Jabarin (Jabarin)
Jabarin is a leader or o icial of HAMAS.
Turkey-based Jabarin is the head of HAMAS’s Finance O ice. In this capacity, he manages
HAMAS’s yearly budget amounting to tens of millions of dollars, is in charge of all HAMAS’s
income from various elements around the world, and seeks to obtain additional sources of
funding for HAMAS.
Jabarin has materially assisted, sponsored, or provided financial, material, or
technological support for, or goods or services to, HAMAS.
In his capacity as head of HAMAS’s Finance Department, Jabarin was focused on developing a
financial network in Turkey that would allow HAMAS to raise, invest, and launder money prior to
transferring it to Gaza and the West Bank.
In recent years, Jabarin has promoted HAMAS’s terrorist activities in the West Bank and Gaza
targeting Israel by transferring hundreds of thousands of U.S. dollars in the West Bank to finance

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HAMAS’s terrorist activity. In addition, Jabarin tries to promote business activity and
investments to generate revenue for HAMAS.
Jabarin has served as the primary point of contact between HAMAS and the IRGC-QF. Since
2017, there was growing contact between IRGC-QF and HAMAS o icials focused on increased
funding from Iran.
Jabarin was involved in the transfer of millions of dollars to HAMAS via Redin Exchange, also
sanctioned today and detailed immediately below.

Redin Exchange
Redin Exchange has materially assisted, sponsored, or provided financial, material, or
technological support for, or goods or services to, HAMAS.
As of March 2019, the Turkey-based Redin Exchange and Treasury-designated financial
facilitator Muhammad Sarur were involved in a $10 million dollar transfer to HAMAS’s
operational arm, the Izz-Al-Din Al-Qassam Brigades.
As of mid-2018, Redin Exchange was identified as a key part of the infrastructure used to transfer
money to HAMAS. Throughout 2017, tens of millions of dollars was transferred to HAMAS with
the assistance of Redin Exchange.
In July 2018, Redin Exchange assisted in the transfer of $4 million from the IRGC-QF to HAMAS.
In May 2018, Redin Exchange assisted in the transfer of $2 million from the IRGC-QF and
Hizballah to HAMAS.
In July 2017, a senior HAMAS leader transferred $5.5 million to HAMAS finance chief Zaher
Jabarin via Redin Exchange.

Marwan Mahdi Salah Al-Rawi (Al-Rawi)
Al-Rawi is a leader or o icial of Redin Exchange.
Al-Rawi is identified as Redin Exchange’s Chief Executive O icer (CEO).
In late January 2018, OFAC-designated ISIS financial facilitator Walid Talib Zughayr al-Rawi, was
aware of an approximately $500,000 financial transaction of Redin Exchange administrator
Marwan al-Rawi.

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Ismael Tash (Tash)
Ismael Tash is a leader or o icial of Redin Exchange.
Tash is Redin Exchange’s Deputy CEO and is in charge of Redin Exchange’s foreign relations.
As of January 2019, Tash was a key player in many financial transfers from Iran to HAMAS, and
was highly involved with HAMAS facilitators.
Since at least 2017, Tash has had ongoing contact with a money transfer channel managed by
Treasury-designated HAMAS financial facilitator Muhammad Sarur. This channel has transferred
IRGC-QF money to Hamas and in particular HAMAS’s operational arm in the Gaza Strip.

SMART Ithalat Ihracat Dis Ticaret Limited Sirketi (SMART)
SMART is owned or controlled by Ismael Tash.
Tash is the owner of SMART.
SMART is an import/export limited company and possible front company associated with Redin
Exchange. Both SMART and Redin Exchange share the same Istanbul-based address.

Saksouk Company for Exchange and Money Transfer (Saksouk)
Saksouk has materially assisted, sponsored, or provided financial, material, or
technological support for, or goods or services to, ISIS.
In late 2018, Saksouk handled fund transfers on behalf of Syria-based ISIS members.
In mid-2017, an ISIS financial facilitator and U.S. Treasury-designated Fawaz Muhammad Jubayr
al-Rawi (Fawaz) and an ISIS commander utilized Saksouk to conduct financial operations
throughout the Middle East. ISIS financial facilitators and a iliates were listed as points of
contact for Saksouk branch locations in Syria, Lebanon, and Turkey.
In July 2017, the Syria-based ISIS Immigration Logistics Committee (ILC) attempted to transfer
money to an ISIS ILC a iliate via Saksouk Company.

Al Haram Foreign Exchange Co. Ltd. (Al Haram Exchange)

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Al Haram Exchange has materially assisted, sponsored, or provided financial, material, or
technological support for, or goods or services to or in support of, ISIS.
As of April 2019, ISIS members in Syria received instruction to conduct all financial transactions
with Al Haram Exchange.
As of early 2017, Al Haram Exchange was involved in an ISIS financial transfer between Syria and
Belgium.
As of mid-2017, a Syrian-based ISIS facilitator coordinated a money transfer between the AlHaram Exchange and Fawaz, the owner of the Hanifa Currency Exchange, an entity designated in
December 2016 for being owned or controlled by Fawaz.

Al-Khalidi Exchange (Al-Khalidi)
Al-Khalidi has materially assisted, sponsored, or provided financial, material, or
technological support for, or goods or services to, ISIS.
As of September 2017, ISIS-a iliated al-Khalidi served as a hawala financial exchange o ice. All
locations were run by two individuals who knowingly assisted ISIS members in financial
transfers. Al-Khalidi’s o ice in Mayadin, Syria also served as an internet café for ISIS members in
addition to its function as a hawala money transfer o ice.
As of early 2017, al-Khalidi in al-Raqqah, Syria, and Gaziantep, Turkey were involved in ISIS's
transfer of funds from Iraq through al-Raqqah, Syria, to Gaziantep, Turkey, in support of ISIS. As
of 2017, ISIS also transferred money into Syria via al-Khalidi.
As of late 2016, Al-Khalidi was the most important financial transfer o ice in the region used to
move money to fund ISIS-held areas. Al-Khalidi was the largest financial exchange o ice that
dealt with ISIS. Hundreds of thousands of dollars per day passed through the o ice in Sanliurfa,
Turkey.
As of mid-2016, Fawaz al-Rawi, who was subsequently designated in late 2016 as an ISIS
financier, arranged for cash shipments to Iraq and Turkey. Fawaz al-Rawi was the owner and
operator of Hanifa Currency Exchange in Albu Kamal, Syria, a designated entity, which he used
to store ISIS external funds. Fawaz al-Rawi conducted financial transactions with agents and
transfer currency-exchanges throughout the region, including al-Khalidi exchanges in Sanliurfa,
Turkey.

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As of mid-2015, al-Khalidi’s Istanbul, Izmir, and Sanliurfa branches facilitated money transfers
and transactions for ISIS. During this same timeframe, ISIS maintained a telephone directory of
associates and managers of various ISIS o ices, which included Syria-based locations for alKhalidi Exchange and al-Hebo Jewelry Company, also sanctioned today

Al-Hebo Jewelry Company (al-Hebo)
Al-Hebo has materially assisted, sponsored, or provided financial, material, or
technological support for, or goods or services to, ISIS.
As of late 2017, al-Hebo’s location in Gaziantep, Turkey was involved in an ISIS scheme to
convert gold into cash to more e iciently and secretly send funds via hawalas in Turkey to ISIS
sleeper cells in Iraq and Syria.
As of early 2017, Raqqah-based al-Hebo was a cash transfer business used by ISIS members.
In September 2016, an employee of Raqqah-based al-Hebo likely coordinated a money transfer
on behalf of a now-deceased, Syria-based, ISIS senior operations o icial.

Muhamad Ali al-Hebo (Muhamad)
Muhamad has acted or purported to act for or on behalf of, directly or indirectly, al-Hebo.
As of late 2016, Turkey-based al-Hebo owner, Muhamad, was involved in procuring precious
metals to enable ISIS to produce its own ISIS coinage.
As of late 2016, Muhamad was the General Manager of an al-Hebo location in Raqqah, Syria.
As of early 2016, Muhamad managed the Sanliurfa-based al-Hebo location.
Muhamad has acted or purported to act for or on behalf of, directly or indirectly, al-Khalidi.
As of early 2017, al-Hebo and al-Khalidi were both under the control and management of
Muhamad. During this same timeframe, Muhamad was involved in operating jewelry stores and
money exchange/transfer businesses in Istanbul, Urfa, and Gaziantep, Turkey. These businesses
operated under the name al-Khalidi.
As of late 2016, Muhamad worked at the Raqqah-based al-Khalidi location.
As of early 2016, Muhamad managed the Sanliurfa-based al-Khalidi location.

Mohamad Ameen (Ameen)
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Ameen has materially assisted, sponsored, or provided financial, material, or
technological support for, or goods or services to or in support of, ISIS-Khorasan (ISIS-K).
Ameen is an ISIS-K recruiter who encouraged people to join ISIS-Khorasan (ISIS-K). Ameen told
a Maldivian citizen and digital media member of ISIS-K to go to Afghanistan because the ISIS-K
media group needed him. The ISIS-K digital media member was told he would receive $700
monthly in salary and was responsible for translating material for Ameen.
Additionally, as of April 2019, Maldives-based Ameen was actively engaged in leading ISIS
recruitment through his close lieutenants. Ameen’s subordinates were holding roughly 10
recruitment sessions per week under the guise of Islamic classes at several Malé, Maldivesbased locations, including Ameen’s home. Ameen and his group continued to recruit on behalf
of ISIS from various Maldivian criminal gangs.
Additionally, Ameen is a recruiter and key leader for ISIS in Syria, Afghanistan, and the Maldives.
Ameen used to direct terrorist fighters to Syria, but now sends them to Afghanistan.

Mohamed Ahmed Elsayed Ahmed Ibrahim (Ibrahim)
Ibrahim has acted or purported to act for or on behalf of, directly or indirectly, al-Qa’ida.
Ibrahim, a Brazil-based member of al-Qa’ida, provided facilitation support to al-Qa’ida
members and material support to al-Qa’ida.

Almaida Marani Salvin (Salvin)
Salvin has materially assisted, sponsored, or provided financial, material, or technological
support for, or goods or services to, ISIS-Philippines.
In April 2019, Salvin was arrested in Zamboanga City, Philippines, based on her suspected
unlawful manufacture, sale, acquisition, disposition, importation, or possession of an explosive
or incendiary device. During the raid, the Philippine authorities recovered improvised explosive
device components, as well as bank accounts and passbooks for Salvin linked to ISISPhilippines (ISIS-P) funding.
As of early 2019, Philippine authorities determined Salvin, who was the wife of an ISIS-P leader,
conducted financial transactions, procurement, transportation of firearms and explosives, and
facilitated the recruitment and travel of foreign fighters to the Philippines.
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Muhammad Ali Sayid Ahmad (Ahmad)
Ahmad has participated in training related to terrorism that was provided by ISIS.
In an October 2018 public interview, Ahmad recounted his journey to join ISIS. He stated that he
le Toronto to join ISIS in April 2014 and attended basic training as a new ISIS recruit. In basic
training, he learned how to use small arms. Later he joined a sniper and reconnaissance unit
where he received advanced sniper and reconnaissance training.

SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of these targets that are in the
United States or in the possession or control of U.S. persons must be blocked and reported to
OFAC. OFAC’s regulations generally prohibit all dealings by U.S. persons or within the United
States (including transactions transiting the United States) that involve any property or interests
in property of blocked or designated persons. In addition, persons that engage in certain
transactions with the individual designated today may themselves be exposed to sanctions or
subject to an enforcement action.
Furthermore, pursuant to E.O. 13224, as amended today, all SDGTs are now subject to
secondary sanctions. OFAC can prohibit or impose strict conditions on the opening or
maintaining in the United States of a correspondent account or a payable-through account by a
foreign financial institution that knowingly facilitates a significant transaction for any SDGT, or a
person acting on behalf of or at the direction of, or owned or controlled by, a SDGT.
Identifying information related to today’s action .
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