Counter Terrorism Designations; Issuance of Venezuela-related Frequently Asked Questions

The Office of Foreign Assets Control (OFAC) has published a press release to inform about new sanction measures. Specifically, the Office added seven individuals and one entity to its Specially Designated Nationals and Blocked Persons List (SDN List) pursuant to existing sanction regulations (31 CFR Part 594 and Executive Order 13224) for their engagement in or affiliation with Kata’ib Hizballah, an organization designated by the U.S. Treasury as a terrorist organization. The following persons and entities are affected and now subject to asset freezing measures:
### Newly sanctioned individuals
AL-BAHADLI, Imad Naji (Arabic: عماد ناجي البهادلي) (a.k.a. MOHAMMED, Imad Naji Mohammed), Iraq; DOB 25 May 1975; nationality Iraq; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Passport A10722899 (Iraq) expires 14 Dec 2023 (individual) [SDGT] (Linked To: KATA’IB HIZBALLAH).
AL-HUSAYNI, Ja’far (Arabic: جعفر الحسيني) (a.k.a. AL-HUSSAINI, Jafar), Iraq; DOB 01 Jan 1968; nationality Iraq; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886 (individual) [SDGT] (Linked To: KATA’IB HIZBALLAH).
AL-MAJIDI, Basim Mohammad Hasab (Arabic: باسم محمد حسب المجيدي) (a.k.a. AL-MAJIDI, Basim Hasan), Iraq; DOB 02 May 1969; POB Baghdad, Iraq; nationality Iraq; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Passport G1240293 (Iraq) (individual) [SDGT] (Linked To: KATA’IB HIZBALLAH).
AL-SARAJI, Hashim Finyan Rahim (a.k.a. AL-SARAJI, Hashim Banyan Finyan Rahim; a.k.a. AL-SARAYJI, Ali Abd-al-Zahra Hafiz; a.k.a. UL AWLIYA, Hashim Banyan; a.k.a. „AL WALAI, Abu Ala“), Baghdad, Iraq; Lebanon; DOB 01 Jul 1966; POB Baghdad, Iraq; nationality Iraq; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886 (individual) [SDGT] (Linked To: KATA’IB SAYYID AL-SHUHADA).
ALSKENI, Khalid Kadhim Jasim (Arabic: خالد كاظم جاسم السكيني) (a.k.a. AL-SUKAYNI, Abu-Humayyid), Iraq; DOB 01 Sep 1972; nationality Iraq; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Passport A17876107 (Iraq) expires 01 Feb 2029 (individual) [SDGT] (Linked To: KATA’IB HIZBALLAH).
DARRAJI, Habib Hasan Mughamis (Arabic: حبيب حسن مغامس دراجي) (a.k.a. DARRAJI, Habeeb Hasan Mghames; a.k.a. „AL-DARRAJI, Abu-Rida“), Iran; DOB 18 Sep 1976; nationality Iraq; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Passport A14309260 (Iraq) expires 12 Sep 2026; alt. Passport A15392136 (Iraq) expires 12 May 2027 (individual) [SDGT] (Linked To: KATA’IB HIZBALLAH).
JAHANDUST, Mojtaba (a.k.a. MARGHUB, Mojtaba Jahandust (Arabic: مجتبى جهاندوست مرغوب)), Iran; DOB 15 Apr 1985; POB Tehran, Iran; nationality Iran; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; National ID No. 0072441364 (Iran) (individual) [SDGT] [IRGC] (Linked To: KATA’IB HIZBALLAH).
### Newly sanctioned entity
KATA’IB SAYYID AL-SHUHADA (a.k.a. BATTALION OF THE SAYYID’S MARTYRS; a.k.a. KATA’IB ABU FADL AL-ABBAS; a.k.a. KATA’IB KARBALA; a.k.a. THE MASTER OF THE MARTYRS BRIGADE; a.k.a. „KSS“), Iraq; Syria; Lebanon; Website www.saidshuhada.com; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886 [SDGT].
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OFAC has also published a corresponding statement to announce the reasoning behind the new sanction measures.
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OFAC has also made the following changes to its „Non-SDN Palestinian Legislative Council List“:
STEPANOV, Artem Nikolaevich (Cyrillic: СТЕПАНОВ, Артём Николаевич), Moscow, Russia; DOB 31 Mar 1980; POB Russia; nationality Russia; Gender Male; Secondary sanctions risk: Ukraine-/Russia-Related Sanctions Regulations, 31 CFR 589.201 and/or 589.209; Tax ID No. 504403080602 (Russia) (individual) [UKRAINE-EO13661] [CYBER2] [ELECTION-EO13848] (Linked To: PRIGOZHIN, Yevgeniy Viktorovich). -to- STEPANOV, Artem Nikolaevich (Cyrillic: СТЕПАНОВ, Артём Николаевич), Moscow, Russia; DOB 31 Mar 1980; POB Russia; nationality Russia; Gender Male; Secondary sanctions risk: Ukraine-/Russia-Related Sanctions Regulations, 31 CFR 589.201 and/or 589.209; Tax ID No. 504403080602 (Russia) (individual) [UKRAINE-EO13661] [CYBER2] [ELECTION-EO13848] (Linked To: OOO YUNIDZHET).
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Finally, OFAC has issued several new frequently asked questions in connection with Venezuela-related sanctions. These are quoted below:
FAQ 1144: Does Venezuela General License (GL) 45A authorize U.S. persons to provide certain services, including refueling services, to blocked Conviasa aircraft listed in the Annex of GL 45A that are carrying out non-commercial flights between a third country in the Western Hemisphere and Venezuela?
A: Yes.
FAQ 1143: For the purposes of Venezuela General License (GL) 45A, what does the term “non-commercial” mean?
A: For the purposes of Venezuela GL 45A, “non-commercial” flights mean not-for-profit flights that are not intended to generate a profit for Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A. (Conviasa), or any entity in which Conviasa owns, directly or indirectly, a 50 percent or greater interest.
FAQ 1142: Does Venezuela General License (GL) 45A authorize U.S. persons to provide general maintenance (including repair) services to blocked Conviasa aircraft listed in the Annex of GL 45A?
A: Yes.
FAQ 1141: Does Venezuela General License (GL) 45A authorize U.S. persons to provide certain services, including refueling services, to blocked Conviasa aircraft that are carrying out flights for the exclusive purpose of repatriating Venezuelan nationals from a third country in the Western Hemisphere to Venezuela?
A: Yes.