The United States Department of the Treasury Office of Assets Control (“OFAC”) for the second time in the past week has utilized the Counter Terrorism Sanctions Regulations to designate individuals suspected of engaging in or materially assisting terrorist activities. The effect of this designation is the blocking of the U.S. assets of such individuals and prohibiting U.S. persons from engaging in transactions with the designated parties.

The designations by OFAC are thought to target the financial support networks of al Qai’da in Iraq (AQI), al-Qai’da and Islamic Jihad Union (IJU). The designations came against two individuals based in Europe: Ahmad Khalaf Shabib al-Dulaymi and a German national, Atilla Selek.

According to the Department of the Treasury, Ahmad Khalaf Shabib al-Dulaymi provides financial, material, or technological support to al Qai’da in Iraq and al Qai’da. In March of 2009, al-Dulaymi is alleged to have been involved in the smuggling of weapons and explosives from Syria into Iraq. Furthermore, he is accused of providing funding to the families of AQI fighters killed in Iraq.

Al-Dulaymi is also believed to be in charge of two Al Qa-ida cells in Europe, including one in Romania that financed al-Qai’da in Europe by smuggling cigarettes and coffee. Moreover, al-Dulaymi is believed to have facilitated the movement of money to an AQI financial facilitator in Fallujah, Iraq. Furthermore, al-Dulaymi allegedly carried a letter from bin Ladin to AQI leader Abu Ayyub al Masri, and has acted as an intermediary between AQI and al-Qai’da members surrounding bin Laden.

The other designee, Atilla Selek received military training in Pakistan. Following his training, Selek helped supply IJU with volunteers to engage in terrorist activities, including a plot to bomb U.S. military installations in Germany. Selek was criminally charged in Germany for being a member of a terrorist organization and was sentenced to five years imprisonment upon his conviction.

In addition, to his designation as a Specially Designated National by OFAC, Selek has been designated under the
UN 1267 Sanctions Committee’s Consolidated List of individuals and entities associated with Usama bin Laden, al-Qai’da, and the Taliban.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC litigation. If you have any questions please contact him at 202-280-6370 at 202-351-6161 or ferrari@ferrari-legal.com.