As announced today, there have been new individuals designated pursuant to Executive Order 13224 as Specially Designated Global Terrorists (SDGT). The result of this designation is that the designated parties will have all of their assets under U.S. jurisdiction blocked. Moreover, U.S. persons, wherever located, will be prohibited from engaging in transactions with these individuals. Although the consequences of such designations can be devastating, there is a process available at 31 C.F.R. 501.807 whereby these individuals can seek a reconsideration of their designation.

Those designated today were alleged to be members of an al-Qa’ida network headed by Ezedin Abdel Aziz Khalil, an al-Qa’ida facilitator, who the U.S. government believes is moving money, facilitators and operatives from across the Middle East to South Asia. One of the parties on the receiving end of such movements is believed to be Atiyah Abd al-Rahman, a key al-Qa’ida leader based in Pakistan, who was also designated today.

Khalil (a.k.a. Yasin al-Suri) is believed to be currently living and operating in Iran. According to the U.S. Government, Khalil has collected funding throughout the Gulf and is responsible for the movement of such funds to al-Qa’ida’s leadership in Afghanistan and Iraq. Moreover, he is alleged to have facilitated the travel of recruits for al-Qa’ida from the Gulf to Pakistan and Afghanistan, requiring each operative to deliver $10,000 to al-Qa’ida in Pakistan.

Al-Rahman, on the other hand, is thought to be al-Qa’ida’s overall commander in Pakistan’s tribal areas and the the leader of al-Qa’ida in North and South Waziristan, Pakistan.

Another designee, Umid Muhammadi is alleged to be an al-Qa’ida facilitator and key supporter of al-Qa’ida in Iraq (AQI). According to the U.S. Government, Muhammadi has been involved in coordinating attacks in Iraq and has provided explosives training to extremists. Moreover, he is believed to have received training in Afghanistan on the use of rockets and chemicals.

Salim Hasan Khalifa Rashid Al-Kuwari, another individual designated pursuant to today’s action, is alleged to provide financial and logistical support to al-Qa’ida. Based in Qatar, Kuwari is believed to have provided hundreds of thousands of dollars in financial support to al-Qa’ida and al-Qa’ida operations. In addition, he is alleged to have facilitated travel for extremist recruits.

Another designee, Abdallah Ghanim Mafuz Muslim Al-Khawar, is accussed of working with Kuwari to deliver money, messages and other material support to al-Qa’ida elements. Khawar is also based in Qatar and is thought to have facilitated travel for extremists interested in traveling to Afghanistan for jihad.

Ali Hasan Ali Al-’Ajmi, an alleged Kuwait-based associate of Khalil, was also designated today for his purported provision of financial and facilitation support to al-Qa’ida, AQI and the Taliban. According to the U.S. Government, ‘Ajmi has carried out fundraising in Gulf countries for AQI facilitators and the Taliban. Moreover, he is believed to have facilitated travel for individuals seeking to take part in fighting in Afghanistan.

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.