March 13, 2024

OFAC amends Global Magnitsky Sanctions Regulations and designates network of al-Shabaab facilitators

On March 11, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control announced that the Global Magnitsky Sanctions Regulations had been amended.  The regulations were reissued in their entirety due to the number of sections in the regulations that were updated or added.  The amendments took effect on March 12, 2024 upon publication in the Federal Register.

On the same day, OFAC sanctioned 16 individuals and entities that are part of a business network that allegedly raises and launders funds for al-Qa’ida affiliated terrorist group al-Shabaab.  According to OFAC, al-Shabaab generates more than $100 million per year to support al-Qa’ida ambitions worldwide and is responsible for some of the worst terrorist attacks in East Africa’s modern history that have claimed the lives of thousands of innocent civilians.  The targeted network is reportedly made up of influential businesspersons and companies located in the Horn of Africa, the United Arab Emirates (“UAE”) and Cyprus.  Most of the new designees have ties to Dubai-based Haleel Commodities LLC, also known as Haleel Group, a key financial facilitator for al-Shabaab that has leaders, branches and subsidiaries in Somalia, Kenya, Uganda, and Cyprus that generate and launder funds for the group.

The designations were imposed pursuant to the counterterrorism authority in Executive Order 13224, as amended.  As a result of these designations, all property and interests in property of the designated persons within the United States or within the possession or control of a U.S. person are blocked, and U.S. persons are generally prohibited from engaging in transactions involving a designated person.  Entities owned 50 percent or more by one or more blocked persons are also blocked.

On March 11, 2024, OFAC also issued General License 29 pursuant to the Global Terrorism Sanctions Regulations (“GTSR”), 31 CFR part 594, to temporarily authorize wind down transactions involving Hallel Commodities LLC or entities in which Haleel Commodities owns a 50 percent or greater interest.  The general license authorizes these transactions until April 10, 2024, provided that payments made to blocked persons are deposited into blocked accounts in accordance with the GTSR.

Federal Register – GMSR Final Rule | U.S. Department of Treasury Press Release | General License 29