The US Treasury publishes the details of the sanctions imposed on investors who support the “corrupt Assad regime’s efforts to rebuild”
The designations target individuals and entities seeking to profit from the widespread displacement of Syrian civilians
WASHINGTON – The Office of Foreign Assets Control of the Ministry of Foreign Affairs (OFAC) today imposed sanctions on 24 individuals and entities who actively support Syrian President Bashar al Assad’s corrupt efforts to rebuild.
Today’s rankings are the first step by the Treasury to impose sanctions under the Caesar Act for the Protection of Civilians in Syria of 2019.
The Caesar Act took its name in honor of the brave cameraman who smuggled thousands of pictures outside Syria to document the atrocities committed by the Syrian regime in its prisons, and it strengthens accountability for those who continue Support the Assad regime and its barbaric behavior against the Syrian people.
Today’s actions reinforce the expansion of the restrictive measures against Syria taken by the European Union in January 2019 and February 2020.
Caesar’s Act and other US sanctions on Syria do not hinder activities that bring stability to northeastern Syria.
We will also continue our humanitarian assistance through our various international and Syrian partners, even in areas under the regime’s control.
US Treasury Secretary Steven Mnuchin said, “The United States will not stand idly by while the Assad regime displaces civilians in favor of pro-regime elites.
The Treasury will continue to use its tools and powers to target the Assad regime and its supporters, as they seek to take advantage of the suffering of the Syrian people.
In conjunction with Treasury ratings today, the State Department has identified 15 people according to Section 2 of Executive Order 13894, focusing on those who hinder, obstruct, prevent a ceasefire or achieve a political solution to the Syrian conflict.
Among the current 24 Treasury rankings, OFAC lists nine targets according to the Caesar Act, in addition to executive orders under the Syria Sanctions Program issued by the Office of Foreign Assets Control, due to the significant support they provide to the government of Syria.
During the conflict in Syria, the Assad regime committed innumerable crimes against the Syrian people.
Today, the Treasury and State Department rankings are only part of a full government campaign by the United States aimed at deterring the Assad regime from continuing its attacks against the Syrian people.
Some of today’s rankings are due to the urban change in the lands that the Syrian regime confiscated from the Syrians after displacing them.
After millions of Syrian citizens were forced to flee their homes throughout the Syrian civil war, the Assad regime and its supporters are now pumping resources to build luxury real estate projects on those lands.
To make way for five-star properties, the regime evacuated and bulldozed the property of tens of thousands of residents from areas in Damascus that were until recently close to the working class sympathizers of the opposition.
The government called one of these projects Marota City, the largest investment project in Syria, and it is a multi-million-dollar real estate project that aims to change the demography of the place to a rich and pro-regime demographic.
Treasury actions today reveal individuals and entities, including public-private partnerships, who seek to benefit from this displacement and reconstruction.
The Syrian government also granted a long-term contract to two men who are friendly businessmen to the system to build and manage “Grand Town” which is a “luxurious tourist city” near Damascus airport, full of planned amenities such as five-star hotel, golf course, a number of villas and a shopping center.
Damascus Sham Holding Company and the city of Marota
Following the confiscation of lands by the Syrian government, Legislative Decree 19 of 2015 formed the official form of the financing and management model on the basis of which the confiscated lands will be developed, and the Damascus Governorate has established a fully owned entity, the Damascus al Sham Holding Company, to oversee the city of Marota.
Damascus al Sham Holding Company has established a series of joint projects and facilitated the flow of private investment into the process of developing confiscated lands.
The Damascus Governorate contributed only in-kind assets (expropriated lands) and relied on businessmen loyal to the regime for funding, which allowed private investors in Syria to benefit greatly from the luxury projects that were built on lands that the Syrian regime confiscated from its people.
In each of these joint ventures, the Damascus Governorate is awarded a share of the profits of Damascus Sham Holding Company.
Damascus al Sham Holding Company has been included in the sanctions list according to Executive Order No. 13573 as it is an agency or instrument of the Syrian government, or owned by the government of Syria or by an official or officials in the government of Syria, or subject to control, directly or indirectly, to them.
In today’s procedures, the Treasury allocated the head of the Damascus Governorate Council, Adel Anwar al Olabi, for his role in supervising the Damascus al Sham Holding Company and the real estate development project in the city of Marota.
Adel Anwar al Olabi was classified according to Executive Order No. 13573 as a senior official in the Syrian government.
In addition, the Office of Foreign Assets Control (OFAC) rated Damascus al Sham for Management Ltd., which is the executive management entity of Damascus al Sham Holding Company.
Damascus al Sham Management LLC is classified according to Executive Order No. 13573 as it is directly or indirectly owned or controlled by Damascus al Sham Holding Company, or because it works for or on its behalf.
Joint ventures and private sector investments
In January 2018, Damascus al Sham Holding Company established Mirza, a joint venture worth 23 billion Syrian pounds (equivalent to $ 52.7 million at the time of the announcement) in which Damascus al Sham Holding Company owns 75 percent of the shares.
Damascus al Sham Holding Company provided in-kind advances (lands) worth 17.3 billion Syrian pounds (the equivalent of $ 39.6 million).
Mirza will build and invest four plots of land in the residential and commercial city of Marota, with a total area of 60,000 square meters.
Mirza is classified according to Executive Order No. 13573 because it is directly or indirectly owned or controlled by Damascus al Sham Holding Company or because it works for or on its behalf.
In early 2018, Damascus al Sham Holding Company established a new joint venture named Bunyan Private Joint Stock Company (Bunyan) with private investors, namely Apex Development LLC and Tamayez LLC.
The value of Bunyan Company is 15.2 billion Syrian pounds (the equivalent of 34.8 million dollars) at the time of its establishment, and Damascus al Sham Holding owns 60 percent of the shares of Bunyan Company, which will develop two mixed-use real estates on land confiscated in the city of Marota, with a total construction area of 30,000 square meters.
Damascus al Sham Holding Company provided the land to the Apex and Tamayaz companies, who will save money to carry out joint-venture development projects with the Apex and Tamayaz to provide financing.
Bonyan is classified according to Executive Order No. 13573 because it is directly or indirectly owned or controlled by Damascus al Sham Holding Company or because it works for or on its behalf.
Nazir Ahmed Jamal al Din is a 90 per cent shareholder in Apex Development & Projects LLC.
Nazir Ahmed Jamal al Din and two Apex companies were classified and distinguished according to Executive Order No. 13582 for providing assistance and material support to the Syrian government or because of providing financial, material, technology, or goods and services of importance.
Nazir Ahmed Jamal al Din, and the Apex and Distinction companies are also classified according to Caesar’s Act, due to their knowingly providing significant financial, material, or technology support to the Syrian government or knowingly engaging in commercial operations with it (including any entity owned or controlled by the Syrian government) or with a prominent political figure in the Syrian government.
Also in 2018, Damascus al Sham Holding Company established a joint stock company in the name of Rawafed Damascus Private Joint Stock Company (Rawafed) with four companies partly or wholly owned by the uncle of Syrian President Bashar al Assad Rami Makhlouf, a businessman classified by OFAC and the European Union and its close partners.
The companies collectively own 51% of the shares in a project that will develop three properties in the city of Marota, two will be mostly residential and the third will be a commercial project, with a combined building area of 38,000 square meters.
The value of this project is 25.9 billion Syrian pounds (the equivalent of 48.3 million dollars).
The four companies participating in the joint venture are Rami Makhlouf, “Ramak for Development and Humanitarian Projects”, “Construction”,”Timet Trading “and” Wings Private Company”.
Rami Makhlouf owns Ramak, while he controls the rest of the other companies.
As for Rami Makhlouf’s brother, Ihab Makhlouf, who is also classified by the Office of Foreign Assets Control (OFAC) and by the European Union, he is the sole owner of the personal construction company, and both Time and Private Wings have partnered with either Rami Makhlouf or one of his partners.
Each of these companies provided advance financing for the joint venture in favor of the Syrian government, in addition to additional contributions over the next three years.
Ramak Development and Humanitarian Projects LLC, Emaar and Timet Trade LLC, and Wings Private Company were classified in accordance with Executive Order No. 13582 to provide assistance and material support to the Syrian government or because they provided financial, material, technology, or goods and services of importance.
The Ramak Development and Humanitarian Projects Company LLC, the Construction Company LLC, the Timet Trading Company LLC, and the JSC Private Wings Company are classified according to the Caesar Act due to their knowingly providing financial, material or technology support to the Syrian government or knowingly engaging in operations Business with it (including any entity owned or controlled by the Syrian government) or with a prominent political figure in the Syrian government.
Rawafed Damascus Private Joint Stock Company was classified according to Executive Order No. 13582 as being directly or indirectly owned or controlled by Ramak Development and Humanitarian Projects Company LLC, Al Emaar Company LLC, and Timet Company LLC and Wings Private Company or as it works for or on behalf of these companies.
Nader Qala’i and luxury tourism
Nader Qala’i and Khaled al Zubaidi are two Syrian men linked to the Assad regime.
Through their company, al Zubaidi and Qala’i LLC, Qala’i and al Zubaidi are developing and managing Grand Town, a luxury tourism project near Damascus Airport, which is to include, among other amenities, a shopping center, golf course, villas and an entertainment center.
The Syrian government awarded the Qala’i and Zubaidi Company a 45-year mutually beneficial contract to establish and manage Grand Town in exchange for about 20 percent of the project’s revenue.
In addition, Nader Qala’i and Khalid al Zubaidi operate the country’s largest hotel, the luxurious five-star Ebla Hotel, which is owned by the system and will be part of the Grand Town complex.
The Syrian Ministry of Tourism praised the Ebla Hotel project because it provides benefits to the system and investors, and stressed its importance in rebuilding the country.
Ebla Hotel is classified according to Executive Order No. 13582 because it is directly or indirectly owned or controlled by Damascus al Sham Holding Company or because it works for or on its behalf.
Nader Qala’i and Khalid al Zubaidi were classified according to Executive Order No. 13582 because of their financial, material, technology, or goods and services support of importance to support the Syrian government.
In addition, Qala’i and al Zubaidi are also classified under Caesar’s Act because they provide financial, material, or substantial knowing support to the Syrian government or knowingly engage in commercial operations with it (including any entity owned or controlled by the Syrian government) or with a prominent political figure in the Syrian government.
Qala’i, which is close to the higher circles of the regime and has ties with Assad, has a number of commercial projects outside the development of Grand Town, as he owns or controls two holding companies, the Citadel Holding Company registered in Lebanon and has operations in Lebanon and Syria, and the Citadel Holding Company limited liability, it is based in Austria.
These two companies (the Citadel Holding Company and the Citadel Holding Company Limited Liability) are classified according to Executive Order No. 13582 because they are directly or indirectly owned or controlled by Nader Qala’i, or because they work for or on his behalf.
Art House LLC, headquartered in Austria, is classified according to Executive Order 13582 as being owned or controlled directly or indirectly by Citadel Holding Company LLC, by Nader Qala’i, or because it is acting on its behalf or on its behalf.
al Zubaidi and Qala’i LLC were also classified according to Executive Order No. 13582 because they are directly or indirectly owned or controlled by Nader Qala’i and Khaled al Zubaidi, or because they are working on their behalf or on their behalf.
Grand Town, which will share a portion of its revenue with the government of Syria, has been appointed in accordance with Executive Order No. 13582 because it is directly or indirectly owned or controlled by Nader Qala’i and Khaled al Zubaidi or because it is working on their behalf or on their behalf.
The fortifications of two telecom companies are also owned by Telefocus Consultants Inc in Canada and Telefocus SAL Offshore in Lebanon.
Qala’a Investment Holding is an investor in one of Qala’i companies, which is a Syrian-based Qala’i Industries, which is building telecommunications infrastructure and steel structures.
The companies Telefocus Consultants Inc, Telefocus SAL Offshore and Qalai Industries were classified according to Executive Order No. 13582 as being owned or controlled directly or indirectly by Nader Qala’i, or because they are working on his behalf or on his behalf.
Humanitarian assistance and trade to Syria
On April 16, the Office of Foreign Assets Control (OFAC) issued a fact sheet highlighting the most important exceptions, exemptions and authorizations for humanitarian aid and trade under the sanctions programs relating to Iran, Venezuela, North Korea, Syria, Cuba and Ukraine / Russia.
The Fact Sheet also outlines specific guidelines for sanctions programs managed by the Office of Foreign Assets Control related to Personal Protective Equipment (PPE) and other humanitarian assistance associated with Coronovirus 2019 (Covid-19) and trade.
For more information about the scope of requirements for any sanctions programs, the applicability or the scope of any humanitarian assistance mandates, please contact the Offak Sanctions Compliance and Evaluation Division at 800-540-6322 or 202-622-2490, or by email OFAC_Feedback@treasury.gov.
Implications for sanctions
All the property or interests of these people in the United States that are located in, in the possession of, or under their control must be prohibited, and reported to the Office of Foreign Assets Control.
The FCO regulations generally prohibit all transactions of US or similar persons residing in the United States or those who cross it that involve any property or interest in the property of classified persons.
In addition, non-Americans who make certain dealings with persons classified today may also be subject to penalties.
US Department of the Treasury
Public Affairs Office
Press release: June 17, 2020
