On May 30, 2023, the US designated the Al-Fadel Exchange and the Al-Adham Exchange Company, two Syrian money services businesses, for facilitating financial transactions for the Bashar al-Assad regime and its Hizballah and Islamic Revolutionary Guard Corps-Qods Force (“IRGC-QF”) allies, in violation of international sanctions laws. The Office of Foreign Asset Control also designated the three brothers that own and control the Al-Fadel Exchange. OFAC reports that, since 2021, both exchanges have facilitated millions of dollars in transfers to the Central Bank of Syria, a US-designated entity, for the benefit of the Syrian government and President Bashar al-Assad, while the Al-Fadel Exchange, in particular, allegedly transferred payments from the Assad regime to a Hizballah financial official in exchange for shipments of Iranian oil. The designations were imposed by OFAC pursuant to EO 13582 for providing material support to the Government of Syria and pursuant to the Caesar Syrian Civilian Protection Act of 2019 for knowingly providing significant material support or engaging in a significant transaction with the Government of Syria.
As a result of these designations, all property and interests in property of the designated individuals and entities 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 the designated persons.