Yesterday, the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) designated Muhammad Abdallah Hasan Abu-al-Khayr as a Specially Designated Global Terrorist pursuant to 31 C.F.R. Part 594. As a result of this designation U.S. persons are no longer permitted in engaging in transactions with Al-Khayr. If they violate such prohibition, they can be penalized either civilly or criminally. Criminal penalties can include a period of imprisonment. In addition to the ban on U.S. persons from engaging in transactions with Al-Khayr, any assets that he held which were under the jurisdiction of the United States have also been blocked.

This designation by OFAC is part of an ongoing effort to target al-Qai’da’s financial network by targeting what they believe to be a key leader of the terrorist organization’s finance section. In addition to OFAC’s actions, the United Nations 1267 Sanctions Committee also imposed similar sanctions against Al-Khayr.

Al-Khayr is currently named on a list of 85 persons wanted by the government of Saudi Arabia. It’s is alleged that his inclusion on that list is due in part to a role he may have played as an al-Qai’da financial facilitator. Al-Khayr has been accused of transferring hundreds of thousands of dollars for a terrorist attack against U.S. interests. Furthermore, he is alleged to have acted for al-Qai’da in a leadership role by serving on the media committee, as well as, possibly recruiting new members for al-Qai’da. Al-Khayr is a son-in-law of Osama bin Laden and is also believed to have provided services to bin Laden as a bodyguard.

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.