On May 2, 2023, the US Department of the Treasury’s Office of Foreign Assets Control announced the designations of Omar Alsheak and Kubilay Sari, financial facilitators for Syria-based terrorist groups Hay’at Tahrir al-Sham (“HTS”) and Katibat al-Tawhid wal-Jahid (“KTJ”), respectively. HTS and KTJ have also been sanctioned by the United Nations. The OFAC designations were part of a joint action taken with Türkiye to prevent the financing of terrorist groups responsible for the ongoing violence and instability throughout the region. As a result, the Turkish Ministries of Interior and of Treasury and Finance concurrently implemented asset freezes against these facilitators. OFAC designated Alsheak and Sari pursuant to Executive Order 13224, as amended, which targets terrorist groups and their supporters. These designations come just months after US and Türkiye engaged in another joint action in January 2023, which targeted several members of a financial network linked to Abd Al Hamid Salim Ibrahim Ismail Brukan Al-Khatuni, a financial facilitator for ISIS who also recruited for the group.
According to OFAC, Alsheak, who is commonly known as Abu Ahmed Zakour, has been the financial leader for HTS since 2019 and has served in various roles for HTS’s predecessor terrorist group al-Nusrah Front, Al-Qa’ida’s former branch in Syria, since 2003. HTS is reportedly part of a coalition of northern Syria-based religious extremist groups that evolved in 2017 when al-Nusrah Front began merging with other groups in northwestern Syria that opposed the regime of Bashar al-Assad. In 2014, Al-Nusrah Front was designated by the US Department of State pursuant to EO 13224, and HTS was listed as an alias of al-Nasrah Front in 2018. The same year, the UN Security Council 1267 ISIL and al-Qa’ida Sanctions Committee also amended its Al-Nusrah listing to include HTS as an alias.
OFAC also alleges that Sari has been receiving funds in Türkiye on behalf of KTJ since 2018 – funds that have been used to purchase weapons systems such as firearms and mortars and military equipment for terrorist operations. KTJ, which is primarily an Uzbek affiliate of al-Qa’ida, reportedly operates in the Idlib Province in Syria and cooperates with other designated terrorist groups in Syria, including HTS. In 2022, KTJ was designated by the US Department of State pursuant to EO 13224, as amended, and the UN Security Council 1267 ISIL and al-Qa’ida Sanctions Committee .
As a result of the OFAC designations, all property and interests in property of the designees within the United States or within the possession or control of a US person are blocked, and US persons are generally prohibited from engaging in transactions involving designated persons. In addition, entities owned 50 percent or more by a designated person or entity are also blocked, and foreign financial institutions that knowingly conduct significant transactions for the designated entities risk exposure to sanctions.